Swedish Court Rules Against the Swedish Tax Agency, Declares Stamp Requirement for Foreign Bank Accounts Unlawful

In October 2025, the Swedish Tax Agency (“Skatteverket”) lost a case before the Administrative Court of Appeal in Stockholm (“Kammarrätten i Stockholm”) concerning the Agency’s right to require original documents bearing a bank stamp when a taxpayer registers a foreign bank account to receive payments from their Swedish tax account (“skattekonto”). The judgment marks a clear limitation on Skatteverket’s ability to impose formal requirements without explicit legal support.

What is a Swedish tax account?

Under the Swedish tax system, every taxable person, whether an individual or a legal entity, has a personal tax account with the Swedish Tax Agency. The tax account functions in principle like a regular bank account, except that the possibilities for withdrawals and transfers are heavily restricted.

However, it is possible to make a withdrawal from the account to another bank account held by the same person or entity to whom the tax account belongs.

How are withdrawals from a tax account made?

Withdrawals are usually made automatically, for example in connection with tax refunds. It is also possible to request a manual payment, for instance through Skatteverket’s online service “Mina sidor.” This requires that the tax payer has previously registered a bank account for the withdrawals.

Can a withdrawal be made to a foreign (non Swedish) bank account?

Yes, it is fully possible to request withdrawal from a Swedish tax account to a foreign bank account. The Swedish Tax Agency however, applies very strict requirements for this. The Agency has required taxpayers to submit original certificates from the foreign bank, bearing a bank stamp, confirming that the account holder is the same person as the holder of the Swedish tax account.

Such certificates have often been difficult and time-consuming to obtain, particularly since many modern banks no longer issue stamped paper documents. As a result, Skatteverket’s practice has in effect disadvantaged individuals and companies who, for entirely legitimate reasons, do not maintain a Swedish bank account.

The circumstances of the court case

The case before the Administrative Court of Appeal concerned an individual resident in the Netherlands who sought to register a Dutch bank account with Skatteverket in order to be able to make withdrawals from her Swedish tax account.

The Dutch bank was unable or unwilling to issue a stamped certificate verifying ownership of the account. On that basis, the Swedish Tax Agency decided to refuse withdrawal to the account. The Administrative Court of First Instance (“Förvaltningsrätten”) agreed with Skatteverket’s position, but the taxpayer appealed to the Administrative Court of Appeal in Stockholm.

The Swedish Administrative Court of Appeal's assessment

The Administrative Court of Appeal in Stockholm began by outlining the applicable legal framework and noted that, under the Swedish Tax Procedure Act (“skatteförfarandelagen”), Skatteverket must execute a payment (withdrawal) from a taxpayer’s account when the taxpayer provides details of their bank account. Only in exceptional circumstances may the payment (withdrawal) be made in another manner.

The Court observed that the individual in question was resident abroad, that Skatteverket had previously made payments to the same Dutch account, and that there was no information suggesting that the payment could not safely be executed.

Against this background, the Court found that Skatteverket lacked legal grounds to deny the withdrawal. The taxpayer’s appeal was granted, and Skatteverket was ordered to carry out the payment/withdrawal to the Dutch bank account.

Implications of the ruling

The ruling clarifies that Skatteverket may not impose formal requirements without statutory authority. The Agency’s practice of demanding stamped original documents from foreign banks lacks support in law and has clearly complicated matters for taxpayers with foreign accounts.

At a time when digitalisation and automated banking procedures have made stamped certificates increasingly rare, the ruling serves as an important reminder that Swedish authorities must align their administrative routines both with the law and with practical realities.

It should nevertheless be noted that the ruling does not necessarily mean that stamped original documents can be disregarded entirely in every situation. A factor of significance in this case was that Skatteverket had previously made payments to the same account, which likely influenced the Court’s reasoning.

It therefore remains possible that Skatteverket may continue to request similar forms of verification in new cases. However, the judgment makes it clear that ownership of a foreign bank account should be capable of being proven even without stamped originals, for example through electronically issued bank statements or other documentation that reliably establishes who controls the account.