Tax disputes

Occasionally, entrepreneurs and the Swedish Tax Agency may have differing interpretations of tax regulations. In such cases we provide guidance and support to help you navigate the dispute and work towards an effective resolution.

We have a thorough understanding of the laws, handle all appeals, and address any queries from the Tax Agency on your behalf. This allows you to focus entirely on running your business.

Forvis Mazars has a tax litigation group composed of Peter Klintsjö, Fredrik Rosén, Kristoffer Forsberg, Hanna Karlsson and Celia Kylesten.

• Peter Klintsjö was a litigator and legal coordinator at the Swedish Tax Agency until 1998. Since then, he has managed several court proceedings as the legal representative or counsel for clients at all court instances.
• Fredrik Rosén, Head of the group, is a trained associate judge and has worked as one in the Administrative Court of Appeal. For the past 20 years, Fredrik has assisted taxpayers in tax disputes, which, in several cases, have been decided by the Supreme Administrative Court after being granted authorisation for appeal.
• Kristoffer Forsberg previously worked at the Swedish Tax Agency as a decision maker and process manager and has run processes in several areas such as VAT, income tax, employer contributions, payment assurance and tax confidentiality.
• Hanna Karlsson began her career as a tax advisor in 2019 and has also been a law clerk at the Administrative Court in Malmö. Hanna has a law degree from Lund University and is an expert in international individual taxation.
• Celia Kylesten has worked with tax processes at Forvis Mazars since 2022 and has a master's degree in commercial and business law from Linköping University. Celia works primarily in income tax with matters connected to small businesses and individual taxation

We can help you with the following:

• Draft a so-called ‘open disclosure’ in your income tax return to reduce the risk of tax surcharges and supplementary taxation.
• Assist in tax audits.
• Answer queries from the Tax Agency.
• Prepare answers to the Tax Agency’s considerations and proposed decisions.
• Appeal the Tax Agency's decision or request a reconsideration of a decision already made.
• Apply for deferment of payment of taxes and tax surcharges.
• Pursue your case with the administrative courts (the Administrative Court, the Administrative Court of Appeal, and the Supreme Administrative Court).
• Apply for advance tax rulings in matters where a question of law is unclear (Council for Advance Tax Rulings).
• Correspondence with the Swedish Customs Service and appeal the Swedish Customs Service's decision. 

If you have received a decision from the Tax Agency or the Customs Agency, we will do an analysis and evaluate your chances of success in court. The earlier you contact us in your case, the greater your chances of achieving a successful outcome.

Being right and winning in court are not always the same thing. With extensive experience from the courts, the Swedish Tax Agency and hands-on experience, we have the tools to manage and assist with tax processes effectively. We offer a comprehensive solution, for both private individuals, for handling tax matters with the Swedish Tax Agency, customs cases at the Swedish Customs Board and disputes at the general administrative courts.

Forvis Mazars’ tax litigation group is one of Sweden's most successful litigation groups with numerous wins as counsel in the Supreme Administrative Court and the European Court of Justice; HFD 2021 ref. 21 (income tax and VAT), HFD 2021 ref. 52 (VAT and legitimate expectations), HFD 2022 ref. 2 (VAT), HFD 2024 ref. 20 and 3894-23 (income tax, withdrawal taxation requires actual use), HFD 2024 ref.39 (income tax, taxation of foundation), HFD 2024 ref. 40 and 2024 note. 30 (Exemption from tax surcharge), HFD 2024 ref. 44 (Harness racing is an economic activity), CJEU C-781/23 (question of interpretation of Article 251 of the Customs Code).

Contact us at process.se@forvismazars.com if you need help with your case.