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HMRC internal manual

Double Taxation Relief Manual

Sweden: Capital gains

Article 13(2) provides that gains from the disposal of shares or rights in a Swedish company accruing to a resident of the United Kingdom, who is a Swedish national but not also a United Kingdom national, may be taxed in Sweden if he had been a resident of Sweden at any time in the seven years preceding the disposal. If he is also chargeable to United Kingdom Capital Gains Tax on the gain under United Kingdom domestic law, credit is due for the Swedish tax payable against United Kingdom tax on the same gain.

The United Kingdom may tax under its domestic law (TCGA92/S276 (7)) any gains derived by a resident of Sweden on the disposal of certain rights connected with the exploration or exploitation of the sea-bed etc in the continental shelf of the United Kingdom (see Article 13(6)).