Sweden's tax agency is demanding SEK 48.1m from Valuno Group for 2019–2022, arguing profit booked in its Gibraltar subsidiary should be taxed in Sweden. The company will appeal and seek a deferral of payment.
Photo: Peter Liljeroos, chief executive of Valuno Group.
Valuno Group AB (publ) received the final decision of Sweden's tax agency, Skatteverket, on Friday 4 September in a transfer pricing case — that is, how profit should be allocated between group companies in different countries — covering the years 2019 to 2022. The company is listed on NGM Nordic SME in Stockholm and develops infrastructure for cross-border payments, where its Atlas platform connects bank money, stablecoins and settlement on the blockchain.
"The decision was expected, and the question has been known for some time and has been handled in dialogue with Skatteverket. We do not share Skatteverket's assessment and will appeal the decision," says Peter Liljeroos, chief executive of Valuno Group.
"The case is complex and concerns circumstances far back in time. In working on it we have also identified further documentation that we believe supports our position," he says.
The decision imposes a total payment demand of SEK 48,061,040. Of that, income tax accounts for around SEK 23.4m, a tax surcharge for about SEK 20.7m and interest for roughly SEK 3.9m. The due date is 12 October 2026.
The decision also reduces the company's tax loss carryforward. Valuno says it will appeal and at the same time request a deferral of payment.
Skatteverket holds that it was Valuno Group, and not the subsidiary QuickBit Ltd in Gibraltar, that performed the value-creating functions and controlled the material risks in the group's affiliate solution. The profit booked in QuickBit Ltd should therefore, in the agency's view, be taxed in Sweden.
During the period the business was run through QuickBit Ltd in Gibraltar, where the group held the regulatory conditions required to operate a crypto business. The company has told Skatteverket that the business was conducted in and from Gibraltar, that the technical systems were established there, that QuickBit Ltd had local staff, and that customer and supplier agreements were entered into by QuickBit Ltd. Its position is that the subsidiary performed the material functions and bore the material risks, that the profit should therefore be taxed in Gibraltar, and that no incorrect information was submitted.
Valuno has further argued that had the business in reality been run from Sweden, this would, in the company's assessment, have conflicted with the regulatory requirements in force during the period and been incompatible with the structure the group had established in Gibraltar. In that case there would also have been no reason to maintain a licensed subsidiary with an operational structure there.
The dispute does not concern the size of the amounts booked, but how the profit should be allocated between the group companies under the arm's length principle — a legal assessment that may ultimately be settled by a court.
The company disclosed on 13 March 2026 that Skatteverket had issued a proposed decision on amended taxation for 2019 to 2022. Valuno submitted detailed comments on the proposal on 25 May. Skatteverket has now decided in line with the proposal, without changing its assessment in any respect.
On appeal, Skatteverket first reconsiders its own decision, after which the matter passes to the administrative court, förvaltningsrätten. The case concerns historical circumstances under a previous management.
The transfer pricing case is distinct from the VAT decision for the 2021/2022 financial year. There, Förvaltningsrätten in Stockholm granted the company an interim deferral of payment on 26 August 2026, without requiring security. Both cases stem from the same audit.
The appeal comes with a request for deferred payment, and the question of where the profit from the affiliate business belongs may therefore sit in the system for some time before it is resolved.
Sources: Valuno Group
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