Sweden’s expert tax regime: current rules, proposed changes and practical implications

The proposed changes were presented in a public inquiry released by the Swedish Government on 15 January 2025. The purpose of the inquiry was to assess whether the existing rules could be improved in order to stimulate increased investment in research and development in Sweden. One of the key instruments in this context is the expert tax regime, which is designed to attract highly skilled foreign professionals to the Swedish labour market.

The intention was for the new rules to enter into force on 1 January 2026. However, the proposal was not included in the Government’s budget bill in autumn 2025, and the changes therefore did not take effect as planned.

That said, there has been no formal communication indicating that the proposal has been withdrawn entirely. As such, the inquiry’s recommendations remain relevant and may still be implemented at a later stage.

 

What do the current expert tax rules entail?

Under the current framework, a qualifying foreign employee benefits from a tax relief whereby only 75% of their salary is subject to Swedish income tax during the first seven years of work in Sweden. The relief also applies at employer level, as social security contributions are calculated on only 75% of the salary.

To qualify, an employee must meet one of the following criteria:

• Salary rule: The monthly salary must exceed 1.5 times the price base amount (corresponding to SEK 88,800 per month in 2026).
• Competence rule: The individual must be an expert or researcher with specialist skills that are difficult to recruit within Sweden or hold a strategic or senior position within the company (key personnel).

 

Proposed changes to the expert tax

The inquiry proposes several measures aimed at making the expert tax rules more targeted and easier to apply. Key proposed changes include the following:

• The tax relief is increased from 25% to 30%, meaning that only 70% of the gross remuneration would be subject to Swedish income tax.
• The competence rule is proposed to be simplified and clarified so that tax relief is granted only to individuals whose work primarily relates to research and development and who hold a PhD or have equivalent experience relevant to the role.
• The requirement that there must be significant difficulties in recruiting individuals with equivalent competence within Sweden is removed.
• The possibility for experts and other key personnel to qualify for expert tax relief under the competence rule is abolished.
• The application period is extended from three to six months.
• Applicants must not have been resident in Sweden during the preceding ten years, compared to the previous five‑year requirement.
• The restriction preventing Swedish citizens from applying for expert tax relief is removed.
• A limitation is introduced to the seven‑year relief period, meaning that an individual may only benefit from one seven‑year period in total. If the individual leaves Sweden and later returns, the remaining part of the same seven‑year period will resume.
• The salary threshold is proposed to be based on the income base amount instead of the current price base amount and set at 1.1 income base amounts. Based on the 2026 income base amount, this corresponds to SEK 91,740.

 

BDO’s comment on the proposed changes to the expert tax regime

Our assessment is that the proposed changes are positive. The proposed increase in the tax relief is welcome, as it better aligns with international standards for similar tax incentives. The extension of the application period and the removal of the restriction preventing Swedish citizens from applying are also positive developments, which are likely to increase the use of the expert tax regime.

The proposed simplification and clarification of the competence rule are likewise welcome, as this rule has historically been difficult to apply and has resulted in limited predictability. Furthermore, the previously implemented reduction of the salary threshold under the salary rule, effective as of 1 January 2025, means that more key personnel and experts whose roles are not primarily related to research and development may still qualify for expert tax relief, provided that the remuneration requirements are met.