Sweden

Pillar Two implementation

The global minimum tax under the Organisation for Economic Co-operation and Development (OECD) Global Anti-Base Erosion (GloBE) rules and the European Union (EU) Directive 2022/2523 of 14 December 2022 has been implemented in Swedish law and entered into force on 1 January 2024 through the Top-up Tax Act. The Top-up Tax Act has been amended to incorporate subsequently adopted Administrative Guidance with the possibility of retroactive application. To the extent such Administrative Guidance has not yet been implemented into Swedish law, the guidance still applies to the extent it is clarification of a question, etc. that does not require legislation. 

As of 1 January 2026 amendments to the Top-up Tax Act apply, including rules on allocation of CFC taxes, changes to the transitional safe harbour rules and changes to the UTPR application. In addition, the foreign tax credit act (Avräkningslagen) has been amended so that QDMTT tax Further changes, including the side-by-side package, have been proposed and are suggested to enter into force on 1 January 2027.