Moving to the USA from Sweden: tax, social security, your company, pensions and visas

Moving from Sweden to Texas or anywhere else in America means untangling two tax systems, two social security systems and a visa file at the same time. This page walks through what Swedish law and the Sweden-US agreements say at each step, from leaving Swedish tax residence to keeping your aktiebolag and your pension. Read it before you book the flight, because several of these rules are decided by what you do before you leave.

How your Swedish tax residence ends when you move to the US

Leaving Sweden does not switch off Swedish tax on the day you board the plane. Under chapter 3, section 3 of the Income Tax Act you are fully (unlimited) taxable in Sweden if you are resident, habitually stay in Sweden, or used to live there and still have an essential connection (väsentlig anknytning). An unlimited taxpayer is taxed on worldwide income.

Chapter 3, section 7 lists the factors for an essential connection: citizenship, how long you lived in Sweden, lack of a permanent home abroad, a year-round home in Sweden, family in Sweden, business activity, significant business holdings and real property in Sweden. Skatteverket weighs all circumstances, and a single factor can be enough. Citizenship is only one of these factors, not a stand-alone basis of liability, and the rules apply both to Swedish citizens and to foreign citizens who were resident in Sweden.

For five years after departure an essential connection is presumed unless you prove otherwise. The presumption applies to Swedish citizens and to people who lived or habitually stayed in Sweden for at least ten years. After five years you are a limited taxpayer unless Skatteverket finds a continuing essential connection, so keeping close ties can keep you resident beyond that point. Where both countries treat you as resident, residence under the tax treaty decides which country taxes which income.

Population registration runs on a separate track: deregistering does not by itself end Swedish tax liability. The practical steps still matter:

• Notify Skatteverket of a planned stay abroad of one year or more, at least one week before you move, through the e-service or on form SKV 7665.
• For a move outside the Nordic countries, your emigration date is the move date if you reported by then, otherwise the date Skatteverket receives your report.
• You keep your citizenship and your personal identity number.
• File a final Swedish tax return for your last fiscal year in Sweden.
• As a limited taxpayer with Swedish items to declare, you receive a special registration number (GD-nummer).

Exit tax: the Swedish ten-year rule on shares

A 2022 committee directive (Dir. 2022:45) asked an inquiry to consider general rules taxing unrealised gains when individuals emigrate, and whether such rules should replace or supplement the ten-year rule. At that date Sweden had no such general rules; the directive describes the ten-year rule as an extended liability for gains not realised at emigration.

Under the ten-year rule (chapter 3, section 19), you remain taxable in Sweden as a limited taxpayer on capital gains on shares and similar assets if you were resident or habitually stayed in Sweden at any time during the year of sale or the ten preceding calendar years. It covers shares and similar equity rights (delägarrätter) and partnership interests, but not units in securities funds and special funds. Foreign-issued shares are caught only if you acquired them while you had unlimited Swedish tax liability.

If you sell shares taxable under the ten-year rule while living abroad, you must file a Swedish income tax return. A tax treaty can limit Sweden's right to tax such a later sale gain.

One rule bites at the moment you leave: if you deferred a capital gain on a share-for-share exchange, that gain becomes taxable when you stop being resident or habitually staying in the EEA (chapter 48 a, section 11). A move to the US takes you out of the EEA, and Skatteverket's position is that a tax treaty does not affect taxation of the deferred amount.

The Sweden-US income tax treaty

The Sweden-United States income tax convention was signed in Stockholm on 1 September 1994 and entered into force on 26 October 1995; Sweden applies it to income derived on or after 1 January 1996. An amending protocol signed in Washington on 30 September 2005 entered into force on 31 August 2006, and Swedish law (Lag 1994:1617) gives the convention force of law in the wording resulting from that protocol. The IRS lists Sweden among its income tax treaty partners and publishes the treaty, the protocol and the 1994 and 2005 technical explanations.

Article 10 caps the tax the source country may levy on dividends. Benefits are subject to the limitation-on-benefits article (Article 17): a resident is entitled to treaty benefits only to the extent that article provides.

Tie-breaker (Article 4(2)). If both countries treat you as resident, you are resident where you have a permanent home available, then where your personal and economic relations are closer, then where you have your habitual abode, then by citizenship, and otherwise by mutual agreement. A US citizen or green-card holder counts as a US resident under the treaty only with a substantial presence, permanent home or habitual abode in the United States.

Pensions and the saving clause. Private pensions, similar remuneration for past employment and annuities are taxable only in your country of residence (Article 19(1), subject to Article 20 on government service). Social security pensions, including the Swedish allmän tilläggspension, paid to a resident of the other country or to a US citizen are taxable only in the paying country (Article 19(2)). Under the saving clause the United States may tax its residents and citizens as if the convention had not come into effect, and may tax a former citizen or long-term resident under US law for ten years after losing that status; the clause does not affect Articles 9(2), 19(2), 23, 24 and 25.

Social security: the US-Sweden totalization agreement

The US-Sweden social security agreement was signed in Stockholm on 27 May 1985 and entered into force on 1 January 1987. A Supplementary Agreement signed on 22 June 2004 entered into force on 1 November 2007, and Swedish law 2004:1192 gives the amended convention force of law in Sweden.

• Posted workers: an employee sent by an employer with a place of business in one country to the other for a period not expected to exceed 60 months stays only under the first country's social security laws. An employer and its affiliated or subsidiary company count as one employer, provided the work would have been covered by the sending country without the agreement. Coverage is proved by a certificate, issued in Sweden by the National Social Insurance Board or its authorised delegate and in the United States by the SSA.
• Self-employed: if you would be covered in both countries, you are covered only by your country of residence.
• Benefits: where Swedish periods are insufficient, periods in both countries are added together, with four US quarters counting as one Swedish year. On the US side, Swedish periods count towards a US benefit only if you have at least six quarters of US coverage.
• Guarantee pension: totalization does not apply to its basic requirement of three years' residence in Sweden, and the agreement does not export it to the United States.

Outside the agreement, you remain resident for Swedish social insurance only if your stay abroad is expected to last at most one year. Försäkringskassan notes that a person moving abroad will probably no longer be insured in Sweden, depending on country and duration, and it must be told about your move so it can assess continued insurance.

Swedish regions offer healthcare to people resident in the region. As a Swedish citizen living in the US you can still get care that cannot wait in Sweden at Swedish patient fees, and for planned care you need not pay the full cost, provided you use the region where you were registered when you left.

Keeping your Swedish company with a US subsidiary

A common setup is to keep your Swedish aktiebolag and place a US corporation under it. Swedish CFC rules (Income Tax Act chapter 39 a) apply to an owner holding, alone or with related persons, at least 25 percent of the capital or votes of a foreign legal person at the end of the owner's tax year. Income counts as low-taxed if it is untaxed or taxed more lightly than Swedish tax on 55 percent of it as business income of a Swedish limited company; with the state income tax for legal persons at 20.6 percent, that threshold works out at about 11.3 percent of a Swedish-computed profit.

For a US subsidiary the decisive rule is annex 39 a. It lists the United States without any income exception, so a US corporation that is resident and liable to tax in the United States is outside the Swedish CFC rules, even if the 55 percent test is failed. The separate carve-out for genuine establishments in the EEA does not cover the United States, so the annex is the route that applies.

Dividends up to the Swedish parent can be tax-exempt under the participation exemption. Shares owned by a Swedish limited company that is not an investment company can be a näringsbetingad andel, and unlisted shares qualify with no minimum holding and no holding period. Such dividends are not taxable, with exceptions that include a dividend the paying foreign company can deduct as interest or similar. The treaty adds its own rule (Article 23(2)(c)): dividends from a US company to a Swedish company are exempt to the extent they would be exempt if both companies were Swedish, provided the profits were subject to the normal US corporate tax.

On the US side, the treaty caps tax on dividends to the Swedish parent at 5 percent where it holds at least 10 percent of the voting power, and reduces it to 0 percent where it has held 80 percent or more for 12 months and meets the Article 17 tests: being publicly traded or at least 50 percent owned by publicly traded companies, the ownership and base erosion test together with the active business condition, derivative benefits, or a competent authority determination.

If you use a US LLC that has not elected corporate treatment, note Article 1(6): for income through an entity that is fiscally transparent under either country's law, the treaty treats the item as derived by a resident only to the extent that country's tax law treats it as income of a resident.

Swedish pensions and retirement savings when you move to the US

Your income pension, premium pension and supplementary pension are kept whichever country you move to. They can be paid to a foreign account in the currency preset for your country of residence, and as a pensioner abroad you must send a life certificate every year to keep the payments.

The guarantee pension is residence-based (Social Insurance Code chapter 5, section 9) and is paid only to residents of Sweden, with a conditional exception for Canada; the United States is not an exception. Since October 2022 it cannot be taken abroad, and for those already abroad it ended from January 2023. A stay abroad of at most one year can keep it. The income pension supplement (inkomstpensionstillägg) is different: it is kept on a move to a country with which Sweden has a social security agreement, and the United States is such a country.

Under Article 19(2) of the treaty, Swedish public pensions paid to a US resident are taxable only in Sweden, where non-residents pay SINK. The rate was cut from 25 to 22.5 percent from 1 January 2026, a provision in force until 31 December 2026, and is 20 percent from 1 January 2027. Public pensions are taxed only above a monthly tax-free amount of one twelfth of 0.77 price base amounts, SEK 3,799 for 2026. Pensionsmyndigheten withholds the tax: without a SINK decision it withholds preliminary tax, and with one it withholds 22.5 or 0 percent depending on the treaty. You may instead ask to be taxed under the Income Tax Act for the year.

SINK also covers occupational pensions where the earlier work was mainly performed in Sweden, private pension insurance from a Swedish insurer and individual pension savings accounts. Income exempted by a tax treaty is exempt from SINK, however, so a private occupational pension or annuity that Article 19(1) assigns only to the United States as your country of residence is not taxed under SINK.

• Avskattning: if a Swedish pension insurance contract is changed so it no longer qualifies, or is disposed of in breach of its conditions, the capital is taxed as employment income at 1.5 times its value. SINK covers this deemed income, subject to the treaty.
• Contributions after the move: under Article 19(4), if you are not a US national, contributions to a Swedish pension arrangement can be treated in the United States like contributions to a US-recognised plan, provided contributions were paid before you became US resident and the US competent authority agrees the plan generally corresponds to a US-recognised one.

Visas: E-1 and E-2 treaty status, reciprocity and the Visa Waiver Program

Sweden is a treaty country for both E-1 and E-2 visas, in each case entered into force on 20 February 1992. It appears on the State Department's list in 9 FAM 402.9-10 and on its Treaty Countries page.

The State Department's reciprocity schedule for Swedish nationals sets the following terms. Any fee shown is charged in addition to the MRV application fee.

Sweden is also a Visa Waiver Program country: both the Department of Homeland Security and the State Department list it among the countries whose citizens or nationals are eligible to travel under the program, under which travel began on 15 July 1989.

To map these rules onto your own move, book a consultation with Mount Bonnell Advisors or start with the firm's free potential analysis.