The Swedish Tax Agency Nov. 27 issued Statement No. 8-2642615, clarifying the allocation of subsidiary shares to a permanent establishment. The taxpayer sought guidance on when subsidiary shares may be considered assets in the establishment, and whether acquisition-related debt must be charged to the establishment. The Tax Agency stated that allocation should be based on the location of decision-makers responsible for acquiring, financing, and disposing of subsidiaries, and assuming associated risks. On appeal, the Supreme Administrative Court clarified that: 1) subsidiary shares are generally allocated based on acquisition, disposal, and financing decision-making functions; 2) extensive integration between the establishment and …