The Swedish so-called "3:12 Rules"

Own or plan to acquire shares in an owner-managed business with a Swedish tax connection? Skattepunkten helps you understand the 3:12 rules and plan dividends, salary, ownership and a future sale with the whole picture in view.

The rules concern dividends and capital gains on qualified shares in closely held companies, known in Swedish as fåmansföretag. They distinguish capital income from employment income. We explain the Swedish concepts in English and consider any cross-border questions alongside your ownership and plans.

Sara and Sahar Abbasi reviewing business matters at Skattepunkten

Owner-managed companies and personal tax

Want help with Sweden's 3:12 rules?

Tell us about the company, your ownership, where you live and what you are considering. We can then discuss the relevant tax year, the records needed and a suitable scope of assistance. Registration is not an order.

If you have any questions before submitting your registration, you are always welcome to contact us.

Understand the options before deciding

How we help you plan under the 3:12 rules

We consider the company, your work, ownership history and future plans together, rather than looking only at this year's dividend.

Dividend allowance and K10

We help assess the dividend allowance and the records needed for your Swedish personal tax return.

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  • Basic amount and allocation between shareholdings
  • Payroll-based allowance and relevant salary records
  • Unused dividend allowance and acquisition cost
  • Dividends, capital gains and the K10 appendix
  • … and more

Ownership and remuneration

We review who owns the shares, who works in the business and how salary and dividends fit your circumstances.

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  • Assessment of qualified shares
  • Owners, related persons and work in the business
  • Several companies, owners or new shareholdings
  • Tax residence and cross-border ownership questions
  • … and more

Sales and ownership changes

We help you consider the tax implications before a sale, transfer, restructuring or move between countries.

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  • Share disposals and capital gains
  • Family succession, gifts and transfers
  • Holding companies and restructuring
  • Planning before an exit or international relocation
  • … and more

From ownership history to your next decision

How we work

  1. Understand your goals

    You describe the company, your ownership and what you want to do. We identify the Swedish and any international questions that need attention.

  2. Review the records

    We examine shareholdings, salary information, accounts and previous K10 appendices, together with any planned changes.

  3. Assess the alternatives

    We consider the rules for the relevant tax year and explain the tax and practical consequences of the available options.

  4. Agree the next steps

    You receive a clear explanation of the assessment, the work needed and any questions to coordinate with advisers in another country.

Swedish rules explained for international owners

Frequently asked questions about the 3:12 rules

What are the Swedish 3:12 rules?

They are special rules for dividends and capital gains on qualified shares in closely held companies. They determine how income is divided between capital and employment income.

What changed from income year 2026?

A single calculation replaces the previous simplified and main rules for the dividend allowance. It can include a basic amount, a payroll-based allowance, interest on part of the acquisition cost and unused allowance carried forward. Transitional rules and effective dates need checking.

What is the dividend allowance, or gränsbelopp?

It is used to assess how dividends or gains on qualified shares are taxed. The calculation depends on the tax year, ownership and the relevant financial information.

When are shares considered qualified?

Your work, or that of a related person, in the company can be relevant. Ownership, related businesses, outside shareholders and applicable time periods may also affect the assessment.

Should I keep track of K10 even without a dividend?

It is often sensible to prepare and retain the K10 calculation even in a year without a dividend or share sale, to track unused allowance. We can assess what should be filed in your circumstances.

Is taking dividends always better than salary?

No. The comparison depends on your work, the company's finances, the allowance and your personal position. We compare the relevant alternatives rather than assuming dividends are always the best choice.

What if I live abroad or plan to move?

Your tax residence and any applicable treaty must be considered. Dividends to a non-resident can raise separate withholding-tax questions. A domestic 3:12 calculation alone does not determine your overall tax position in two countries.

Can I claim a full basic amount in several companies?

There is a limit on the total basic amount for an individual with qualified shares in several closely held companies. The allocation needs to be assessed across the relevant shareholdings.

Can you help before a sale or family succession?

Yes. We can review a planned sale, gift, transfer or restructuring, considering the ownership history and timing alongside the intended outcome. The work is tailored to the transaction.

What information should I bring?

Start with the ownership structure, acquisition dates and costs, salary records, accounts and previous K10 appendices. Tell us about relevant countries, your work in the business and any planned dividends, sale or move.

Sara Abbasi at Skattepunkten

Want to plan tax-efficient salary and dividends?

Register as a new client so we can consider how we can help you. Registration is not an order. If you have any questions before submitting your registration, you are always welcome to contact us.

Swedish expertise with international reach

Ownership and personal tax across borders

The 3:12 rules are Swedish, but your ownership, work or residence may involve another country. As a member of ETL GLOBAL, Skattepunkten can coordinate with relevant local specialists when the assignment calls for it.

You retain a clear Swedish contact while the Swedish assessment is connected with the information and advice needed in the other countries involved.

Read more about ETL GLOBAL

This page provides general information, not an assessment of your shareholding or tax residence. The relevant rules and amounts depend on the tax year, ownership, activities and circumstances. Cross-border situations also require consideration of the other country's rules and any applicable treaty.