STRENGTHENED TAX INCENTIVES FOR R&D

Under the current rules, employers of persons working with qualifying R&D receive a relief from employer social security contributions of 20% of the salary basis, capped at SEK 3 million per group and calendar month. The employee must work with R&D at least half of their working time and at least 15 hours per month, and the statutory definitions of research and development have proved both narrow and litigation-prone.

The first referral broadens and simplifies the definitions of research and development and abolishes the 15-hour monthly minimum, while retaining the requirement that at least half of working time is spent on R&D. The Tax Agency is to request an opinion from another authority where needed to assess whether work constitutes R&D. The same referral also proposes more generous expert tax relief: the tax-free portion of a qualifying expert’s salary is increased from 25% to 30%, the relief is extended to Swedish citizens, the requirement that comparable competence is difficult to find in Sweden is removed, and the seven-year application period may be split over several periods of stay.

The second referral proposes a voluntary enhanced cost deduction in corporate income taxation corresponding to 200% of qualifying salary costs for R&D staff, provided the work is performed within the EEA. Together with the ordinary deduction, qualifying salary costs may be deducted at 300% in total — a tax benefit corresponding to 41.2% of those costs. No cap is proposed.

Both referrals are set to come into effect on 1 January 2027, subject to the final outcome of the Swedish general election, the new government and the available fiscal space.