Stockholm, Oslo, Copenhagen: India's 2024-26 Changes, Condensed

India-Sweden DTAA: 10% interest, 10% dividends.

India-Norway DTAA: 10% interest, 10% dividends.

India-Denmark DTAA: 15% interest, 15% dividends (Article 11(3)(a) carves out 10% only when the beneficial owner is a bank/financial institution; for individual NRO FD holders, 15% applies).

All three treaties are stable through 2024-26. Capital gains are source-country taxed. TRC processes:

All three are digital and take 2-4 weeks.

**Section 148 reopening** cut to 3 years 3 months / 5 years 3 months from the older 10-year cap, effective 1 September 2024.

**Section 151A faceless mandate** confirmed by Supreme Court (July 2025). JAO-issued Section 148 notices are void.

**Budget 2024 LTCG** — 12.5% flat, no indexation, on NRI property sales from 23 July 2024 (NRIs not eligible for the resident-only 20%-with-indexation election).

**Black Money Act safe harbour** raised to ₹20L for movable foreign assets, 1 October 2024 (Finance (No. 2) Act 2024 amendment).

These changes apply regardless of whether you're in Stockholm, Oslo, or Copenhagen. Your treaty rate stays the same; the administrative plumbing around it has moved.

Skatteverket (Stockholm), Skatteetaten (Oslo) and Skat (Copenhagen) all issue TRCs through their respective digital portals. MinSide, Altinn, and TastSelv Borger. Turnaround is usually 2-4 weeks, free, no paper. Most Nordic Indians never apply because the community is small and the Indian CAs they use aren't set up for the workflow.

For past-year recovery the Section 119(2)(b) condonation window reaches back 5 Assessment Years. A Nordic NRI who's been filing at default rates since 2020 can claim the treaty rates on every one of those years in a single consolidated condonation application. The 244A interest at 6% simple adds roughly another 18% on top of the refund.

All of this runs through a Section 288 Authorized Representative, no Skype calls with an AO, no flights to Mumbai.