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Leaving home

Leaving Sweden with a US LLC

Sweden's five-year presumption, the ten-year rule on share gains, CFC rules and the exit-tax debate: what Sweden still claims after you leave.

Sweden has no exit tax for individuals. What it has instead reaches further than many leavers expect: a presumption that keeps you an unlimited taxpayer for five years after you go, and a rule that keeps gains on your shares taxable in Sweden for ten years. Both bear directly on a US LLC you set up before, or just after, you leave.

Three ways to stay an unlimited taxpayer

Under chapter 3, section 3 of the Income Tax Act (inkomstskattelagen, IL) you are an unlimited taxpayer if you

  1. are resident in Sweden,
  2. stay in Sweden on a continuous basis, or
  3. have an essential connection (väsentlig anknytning) to Sweden and previously lived there.

An unlimited taxpayer is taxable on all income from Sweden and from abroad (3 kap. 8 §), and Skatteverket expects all of it, Swedish and foreign, in the Swedish income tax return. The third ground is the one that catches people who have already left.

Essential connection and the five-year presumption

IL 3 kap. 7 § lists what is weighed to decide whether a former resident has an essential connection:

Skatteverket weighs all circumstances together and says that an essential connection can exist even if only one of these applies.

The second paragraph of the same section reverses the burden of proof. For five years from the day you leave, you are deemed to have an essential connection unless you show that you do not. This applies to Swedish citizens and to anyone who lived or stayed in Sweden on a continuous basis for at least ten years. After the five years, Skatteverket says, you are a limited taxpayer unless it assesses that an essential connection still exists.

Deregistering does not settle any of this. Tax liability and population registration (folkbokföring) are two separate systems, each with its own concept of residence, and you can owe Swedish tax even though you are no longer registered in Sweden.

The ten-year rule (3 kap. 19 §)

Even once you are a limited taxpayer, you remain taxable in Sweden on capital gains on covered assets if at any time in the calendar year of the sale, or in the ten preceding calendar years, you lived in Sweden or stayed there on a continuous basis.

Covered: shares and similar equity rights (delägarrätter), interests in Swedish trading partnerships, and interests in foreign legal persons that are taxed at member level abroad.

Excluded: units in securities funds and special funds, and equity held in an investment savings account (ISK), subject to exceptions.

Foreign holdings: shares issued by foreign companies and interests in foreign legal persons taxed at member level are covered only if you acquired them while you were an unlimited taxpayer in Sweden.

For your LLC this has a direct consequence. An interest in a US LLC acquired while you were Swedish-resident can fall under the ten-year rule if the LLC is a foreign legal person taxed at member level. How Sweden classifies a particular LLC is not settled in the sources checked for this page, so treat that as open. And keep the timing in mind: if the five-year presumption still makes you an unlimited taxpayer when you form the LLC, the interest is acquired while you are unlimited.

Tax treaties often cut the rule back. The government's own 2022 directive notes that Sweden's claims under the ten-year rule are in many cases limited by tax treaty provisions. Read the treaty with your new country before you sell anything.

CFC rules and member-level taxation

While you are an unlimited taxpayer, chapter 39 a (the CFC chapter) can reach a foreign company you hold:

Foreign legal persons that are taxed at member level abroad are not treated as legal persons for the CFC chapter. They fall under IL 5 kap. 2 a § instead: unlimited taxpayers who are members of such an entity are taxed on its income directly. The definition is a foreign legal person whose income is taxed to its members in the foreign state where it belongs. Which of the two routes applies to your LLC depends on that classification, which this page does not settle. Both routes bind you only while you are an unlimited taxpayer.

That ends with unlimited liability. A limited taxpayer counts as a CFC shareholder only if the shares belong to a permanent establishment in Sweden.

The exit-tax debate: proposals, not law

No exit tax for individuals is enacted. The official record so far:

None of this is law. If your move is still some years away, watch the ten-year rule: that is where the committee says work is under way.

Deregistering from folkbokföring

If you can be expected to spend your nights outside Sweden regularly for at least one year, you are deregistered as emigrated. You must notify Skatteverket at least one week before departure, stating the departure date, through the e-service or on form SKV 7665 "Anmälan - Flyttning från Sverige" (English version SKV 7665b). For a move outside the Nordic region you are registered as emigrated from the day you move if you notify by that day; otherwise from the day Skatteverket receives the notice. Your citizenship is not affected and you keep your personnummer.

Skatteverket also points out that you may still have to file a Swedish income tax return after you no longer live or stay in Sweden.

The right sequence

Notify Skatteverket at least one week before departure, with the departure date, through the e-service or form SKV 7665 (SKV 7665b in English).Cut the connection factors you control: the year-round dwelling, family in Sweden, business in Sweden, holdings that give you significant influence over a Swedish business, real property.If you are a Swedish citizen or lived in Sweden ten years or more, keep the evidence that you have no essential connection: for five years, the burden of proof is yours.While you remain an unlimited taxpayer, file Swedish returns with all your income, Swedish and foreign, and check the CFC and member-level rules for the LLC.Before selling shares, or an LLC interest acquired while you were unlimited, within ten years of leaving, check the ten-year rule and the treaty with your new country.

What goes wrong if you skip a step

How the LLC is taxed on the US side is explained in how the LLC is taxed. Neighbouring countries: Norway, Denmark, Finland.

Sources

Checked 26 October 2026.

Your own case

This page is general information, not advice on your case. Your connection factors, your holdings and the treaty with your new country are checked in the consultation, held in English.

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