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Sweden: VAT position statement clarifies final payment responsibility and expense handling

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The Swedish Tax Agency published Position Statement No. 8-112199-2025, addressing the issue of VAT payment responsibility when specified in law but not reflected on the invoice, and clarifying the VAT treatment of reimbursed expenses. The new position statement replaces Position Statement No. 131 471453-05/111 from 2005.

Key clarifications include:

  • Reimbursed expenses:
    Amounts received by a taxable person from the acquirer as reimbursement for expenses incurred in the name and on behalf of the acquirer—and recorded in a suspense account—are not included in the taxable amount under EU Directive 2006/112/EC.

  • Supporting documentation and VAT deduction:
    The taxable person must provide evidence of the actual expense amounts. However, the VAT charged on those expenses is not deductible by the taxable person.

  • Guarantee and service classification:
    A guarantee covering goods supplied affects the classification of a transaction as a supply of services for consideration only if it influences a criterion set out under Article 2(1)(c) of the directive, according to the Court of Justice of the European Union (CJEU).

The position statement provides updated guidance on VAT liability and compliance in cases where invoicing and legal provisions may not fully align.

Source: skatteverket.se

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