Field Notes

concept

Utdelning i fåmansföretag

A Swedish closely held company — a fåmansföretag — can distribute profit to its owners as dividends rather than paying it out as salary. Because the two routes would otherwise be taxed very differently, a body of rules known from its former statutory location as the 3:12 rules caps how much an owner of qualified shares may take at the favourable capital rate. That cap is the gränsbelopp, the dividend allowance.

Dividends within the allowance are taxed by taking two thirds into the capital income category, where the rate is 30 percent. The effective rate is therefore 20 percent: a dividend of 100,000 SEK inside the allowance carries 20,000 SEK of tax.1 Distributions above the allowance are taxed as employment income, which is what stops the dividend route from simply replacing salary and its Arbetsgivaravgifter.

Unused allowance is saved and carried to later years.

The 2026 reform

The rules changed substantially from income year 2026, first reported in the return filed in 2027.1 The previous choice between a simplification rule and a main rule was abolished, and one calculation replaced both.

The allowance is now the sum of four parts:

Part Basis for income year 2026
Base amount Four IBB of the preceding year: 4 x 80,600 = 322,400 SEK
Wage-based space 50% of the owner’s share of the wage base above eight IBB, a deduction of 644,800 SEK
Interest on acquisition cost Government borrowing rate plus 9 points, on the part exceeding 100,000 SEK
Saved allowance Carried forward, no longer uprated with interest

The base amount is divided equally across the shares in the company, so a sole owner takes all 322,400 SEK of it. The government borrowing rate fixed on 30 November 2025 was 2.55 percent, giving 11.55 percent for the 2026 calculation.1

Two of the changes narrow rather than widen the allowance. Interest may now be computed only on acquisition cost above 100,000 SEK, and saved allowance stops accruing interest, so an owner with a large carried balance loses growth that the previous rules gave automatically.

Why the salary comparison still has to be made

The dividend route is not simply cheaper than salary. The company pays corporate income tax at 20.6 percent on the profit before any of it is distributed,2 so the 20 percent capital rate applies to money already taxed once. Salary is a deductible company cost carrying Arbetsgivaravgifter at 31.42 percent, and it builds pension entitlement and social-insurance cover that a dividend does not.

The wage-based part of the allowance ties the two together: paying salary is what creates room to take a larger dividend at the capital rate in the first place, so an owner minimizing salary can shrink next year’s allowance. An owner-remuneration plan is a calculation across both routes and across years, not a preference for one of them.

Swedish business tax map routes between the layers, and the arithmetic for a specific company is work for a Swedish accountant rather than a wiki note.


  1. Skatteverket, ändrade regler för delägare i fåmansföretag, captured 2026-07-29 in Skatteverket business tax pages 2026

  2. Skatteverket, belopp och procent 2026, which gives the corporate income tax rate as 20.6 percent. 

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