Under the general rule, the income of a controlled foreign entity is deemed to be subject to low taxation if it is not taxed at all or is subject to tax that is lower than 12,1% (55% of the Swedish tax rate of 22%. for income year 2018). However, income is not considered to be subject to low taxation if the foreign legal entity is a tax resident, and liable to income tax, in one of the countries listed in a white list, provided that the income in question has not been expressly excluded in the list. In addition, the CFC regime does not apply to income derived from a foreign legal entity engaged in international shipping activities, provided that also the shareholder is engaged in shipping activities, whether directly or indirectly through a legal person resident in the EEA.