Panama, Vietnam off EU list; interest ban end-date clarified

Skatteverket has updated its legal guidance on the interest deduction ban for companies in non-cooperative jurisdictionsSkatteverket with two 16 October 2026 entriesSkatteverket. Panama and Vietnam have been removed from the EU list of non-cooperative jurisdictions in the update of 16 October 2026Skatteverket, and the country list on the page has been revised accordingly: Panama is now listed as covered up to and including 15 October 2026Skatteverket, while the Fiji and Samoa end dates are corrected to 5 March 2026 and Turks- och Caicosöarna is shown as covered from 5 March 2026.

The second entry clarifies the removal-date rule in 24 kap. 15 b § inkomstskattelagen: where a country no longer appears in the list published in the Official Journal of the European Union (EUT) on a given date, the country is removed from that dateSkatteverket. The ban therefore covers interest accruing up to and including the day before publication in the EUTSkatteverket, but not interest accruing on the publication day itself or laterSkatteverket. The assessment is always made against the list as in force and published in the EUT; Skatteverket's update of the legal guidance does not itself govern deductibility.

The ban covers interest expenditure, defined as interest and other credit costs plus comparable expenditure under 24 kap. 2 § IL, on both internal and external debts owed to companies resident in a listed jurisdiction. Company here means legal persons and Swedish trading partnerships. Deductibility denied under this ban is assessed before the targeted interest deduction limitation rules, and the rule has no equivalent of the beneficial-owner look-through: interest channelled through a company in a non-listed country to a company in a listed country is not caught.

A treaty carve-out remains: where Sweden has a tax treaty with a listed country containing a non-discrimination clause matching Article 24(4) of the OECD Model Convention, the ban cannot be appliedSkatteverket. During parts of 2026 this concerns Vietnam, which cannot be subject to the banSkatteverket. The applicable countries for 2026 are otherwise Amerikanska Samoa, Anguilla, Guam, Palau, Ryssland, Amerikanska Jungfruöarna and Vanuatu for the full year, plus the date-bounded Fiji, Samoa, Panama and Turks- och Caicosöarna entries.

Legal basis: 24 kap. 15 b § (first and second paragraphs), 24 kap. 2 § and 24 kap. 15 a § inkomstskattelagen (1999:1229); prop. 2020/21:26; the EU list of non-cooperative jurisdictions as published in the EUT.