Open-water swim package taxed at 13.5% as sports access

The Central Tax Board (Centralskattenämnden) has ruledVero that an open-water swimming facility's service package, sold for a single admission feeVero, is one supply taxed at the reduced 13.5% rateVero under section 85(1)(8) of the VAT Act (mervärdesskattelagen)Vero. The advance ruling CSN:029/2026Vero applies for 23 September 2026 to 31 December 2027 and is not yet final (Ej lagakraftvunnen).

The question was whether the reduced rate in 85 § 1 mom. 8 punkten applies to the service package described in the company's application: for an admission fee called a swim ticket, customers received bathing and year-round open-water swimming in a delimited area. The company held a water area in a lake, marked off with floating lines, with two 25-metre lanes; the swimming area matched the area of indoor pool basins. The ticket also covered sauna bathing, changing rooms, showers and toilets, flotation belts, valuables lockers, three sunken hot-cold pools, a lit snow-free walkway and a heated jetty. Three custom pumps kept the area ice-free below freezing, and the company maintained the site by clearing litter, preventing slippery surfaces and servicing jetties and equipment.

Considering the service as a whole, the Board held that from the average consumer's perspective the principal supply was the transfer of the right to use premises and areas suited to swimming — that is, exerciseVero. The other components included in the price, such as sauna bathing and the use of changing, shower and toilet facilities, were merely a means of enjoying the principal supply, swimming, under the best possible conditionsVero.

The services in the application are therefore a single packageVero whose principal supply is the transfer of the right to use the open-air bathVero, taxed at 13.5%Vero under 85 § 1 mom. 8 punktenVero. The reduced 13.5% rate applies to the listed services and goods under section 85, whose introductory paragraph was amended with effect from 1 January 2026. The ruling cites the VAT Act (1 § 1 mom. 1 punkten, 84 § and 85 § 1 mom.), Article 98(1) of the VAT Directive with its Annex III list of supplies eligible for reduced rates, and CJEU judgments in C-432/15 Bastová, C-215/19 (Enheten för bevakning av skattetagarnas rätt) and C-276/09 Everything Everywhere.

Legal basis: mervärdesskattelagen (1501/1993) 1 § 1 mom. 1 punkten, 84 § and 85 § 1 mom.; Council Directive 2006/112/EC, Article 98(1) and Annex III; CSN:029/2026 (23.9.2026–31.12.2027, not final).