AOW and pension in Sweden: the treaty is about to tip — but not yet

Whoever reads about pensions in Sweden reads about two treaties at once: the treaty of 1991 that applies today, and the treaty signed on 24 June 2026 that is going to turn things around. Knowing the difference means planning better.

Today: the treaty of 1991

Under the treaty in force, the division is favourable and clear. Article 18 allocates pensions and annuities — the article names annuities explicitly — exclusively to your state of residence: Sweden taxes, the Netherlands lets go. You apply to the Belastingdienst for an exemption certificate for wage tax, and from then on your pension fund pays out gross.

Two exceptions complete the picture. Payments under social security — your AOW (the Dutch state pension) — may be taxed by the paying state: so that one stays Dutch, through wage tax. And the government pension (ABP from public-sector employment) likewise remains taxed in the Netherlands. For assets the familiar pattern applies: a rented-out house in the Netherlands remains fully taxed in the Netherlands (article 6), on dividends the Netherlands as source state may withhold 15% (article 10), and interest is exclusively for your state of residence — on Dutch savings interest only Sweden taxes (article 11).

Tomorrow: the treaty of 24 June 2026

On 24 June 2026 the Netherlands and Sweden signed a new tax treaty that replaces the treaty of 1991. The biggest change hits precisely this chapter: the Netherlands may from then on tax all pensions built up in the Netherlands — so including the occupational pension that is still taxed exclusively in Sweden today. With that, the Netherlands extends the line it has been negotiating into new treaties for years.

But signed is not in force: the treaty still has to pass the Council of State and both parliaments, and until that ratification is complete the treaty of 1991 applies in full. The lesson for whoever leaves now: plan on the old treaty, but count on the tip for the long term — the exemption certificate you get now is not a lifelong promise.

The Swedish side: declare, and count in

As a resident of Sweden you declare your worldwide income, including your Dutch pensions — Skatteverket says it bluntly: income from home and abroad. Pension is taxed there as earned income, in a system that is easy to summarise: up to the state-tax threshold the tax office keeps roughly three hundred of every thousand kronor, above it roughly five hundred. What the Netherlands already taxed under the treaty is credited via the treaty. How exactly those two systems bite into your mix is the one conversation with a tax adviser that every corridor deserves.

The healthcare side: the factor that jumped to 1.0

Pensioners without work in Sweden fall under the CAK treaty route: with the S1 form you register in the Swedish system, at the expense of the Netherlands, against a treaty contribution. That contribution follows the country-of-residence factor, and there lies a silent cost increase: for Sweden it still stood at 0.7751 in 2022, in 2026 at 1.0000 — Swedish healthcare is by now priced as expensive as Dutch healthcare in this system, and you notice that in the monthly contribution. And one deadline dominates the planning of early retirees: from — expectedly — 1 November 2026, early retirement no longer gives access to the CAK route; whoever is registered before then keeps their rights.

The protective assessment on your pension and annuity accrual is a formality within the EU: automatic deferral, no securities, and after ten years without surrender, remission on request. You file the M return for the year of emigration online — keep your Dutch annual statements, because it only comes the year after.