Pillar 2 Dashboard: Sweden

Overview

Law

Domestic Rules

Filing & Payment

Domestic Returns

OECD Administrative Guidance

QDMTT Design

CbCR Safe Harbour Design

Overview

Law

Domestic Rules

The purpose of the Minimum Tax Act is to implement the EU Minimum Tax Directive into domestic law.

Whilst the EU Minimum Tax Directive is based on the OECD Model GloBE rules, it does not reflect many aspects of the OECD Administrative Guidance. As Sweden has opted just for a transposition of the terms of the Directive, it did not reflect many aspects of the OECD Administrative Guidance (either the February 2023, July 2023 or December 2023 guidance issued). These are, however, included in the December 2024 Amendment Law.

Similarly, only the Transitional CbCR Safe Harbour (as provided in the December 2022 Safe Harbour and Penalty Relief Guidance) was included in the Minimum Tax Act. The GloBE Safe Harbours as provided in the OECD Administrative Guidance (QDMTT Safe Harbour, the Transitional UTPR Safe Harbour and the NMCE Simplified Calculations Safe Harbour) are included in the December 2024 Amendment Law.

Administrative Guidance

The Minimum Tax Act does not include many aspects of the First, Second, Third or Fourth Set of OECD Administrative Guidance.

The following are, however, included in the December 2024 Amendment Law:

-Sovereign wealth funds and the definition of Ultimate Parent Entity (Article 1.4);

-Clarifying the definition of ‘Excluded Entity’ (Article 1.5);

-Meaning of “ancillary” for Non-Profit Organisations (Article 1.6);

-Forex hedge election (Article 2.2);

-Excluded dividends – asymmetric treatment of dividends and distributions (Article 2.3);

-Debt release election (Article 2.4);

-Covered Taxes on deemed distributions (Article 2.6);

-Excess negative tax carry-forward guidance (Article 2.7);

-Substitute Loss carry forwards (Article 2.8);

-Equity Gain or loss inclusion election (Article 2.9);

-Allocation of taxes arising under a Blended CFC Tax Regimes (Article 2.10);

-The extension of the taxable distribution method election to insurance investment entities (Article 3.1);

-Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity (Article 3.2);

-Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders (Article 3.4);

-Portfolio shareholding election (Article 3.5);

-Application of Tax transparency election to Mutual insurance companies (Article 3.6).

-Currency Conversion Rules (Article 1 of the Second Set of OECD Administrative Guidance );

-Tax Credits Guidance (MTTCs) (Article 2 Second Set of OECD Administrative Guidance);

-SBIE Rules

-Foreign rules (Article 3 Second Set of OECD Administrative Guidance);

-Stock-based compensation election;

-Leases (Article 3 Second Set of OECD Administrative Guidance).

The following aspects of the December 2023 OECD Administrative Guidance are included in the December 2024 Amendment Law:

-Transitional CbCR – Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment)

-Transitional CbCR – JVs

-Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting

-Transitional CbCR – Using different accounting standards

-Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Misatches

-Transitional CbCR – MNEs not required to file CbC Reports

-Transitional CbCR – Qualified Financial Statements for PEs

-Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities

-Transitional CbCR – Treatment of hybrid arbitrage arrangements

-Blended CFCs – multiple GloBE Jurisdictional ETRs

-Blended CFCs – not required to calculate an ETR

-Blended CFCs – income of non-GloBE Entities

-30 June 2026 filing deadline

-NMCE Simplified Calculations

The Minimum Tax Act also includes:

-Currency Conversion Rules under Article 1.1 of the February 2023 OECD Administrative Guidance;

-Exclusion of the State from the definition of an Entity under Article 1.2 of the February 2023 OECD Administrative Guidance;

-Accrued Pension Expenses under Article 2.5 of the February 2023 OECD Administrative Guidance;

-The extension of Additional Capital to include Restricted Tier One Capital under Article 3.3 of the February 2023 OECD Administrative Guidance;

The August 2025 Draft Amendment Law includes proposed changes to implement the June 2024 OECD Administrative Guidance. This includes specific amendments for:

Edit
Fourth Set of OECD Administrative Guidance (Article)	Rule	Implementation in Sweden
1.2.1	Aggregate DTL Category basis	Applicable under general interpretative provisions
1.2.1	Exclusion of certain types of GL accounts and separate tracking	Applicable under general interpretative provisions
1.2.1	Exclusion of GL accounts that generate standalone DTAs	Applicable under general interpretative provisions
1.2.1	Exclusion of swinging accounts and separate tracking	Applicable under general interpretative provisions
1.2.2	FIFO/LIFO Basis	Applicable under general interpretative provisions
1.2.3	Aggregation of Short-term DTLs	Applicable under general interpretative provisions
1.2.2	Reversal of DTLs that accrued before the Transition Year	Applicable under general interpretative provisions
1.2.2	5 year unclaimed accrual election	Applicable under general interpretative provisions
2.1.2	Recalculated deferred tax where GloBE carrying value differs from accounting carrying value	Ch.3, 30a – Draft 2025 amendment bill
2.1.2	GloBE and accounting carrying values and the Transition Rules	Ch.3, 30a – Draft 2025 amendment bill/general interpretative rules
2.1.2	Additional provisions for Intragroup transactions accounted for at cost	Ch.3, 30a – Draft 2025 amendment bill/general interpretative rules
2.1.2	Exclusion of GloBE carrying value from SBIE	Ch.3, 30a – Draft 2025 amendment bill/general interpretative rules
3.1.3	General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps	Ch.3, 27a -27d – Draft 2025 amendment bill
3.1.3	Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income	Ch.7, 25a -25f – Draft 2025 amendment bill
3.1.3	Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries	Ch.7, 25a -25f – Draft 2025 amendment bill
4.1	Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids	Ch.3, 34c – Draft 2025 amendment bill
4.2	Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE Hybrid or Rev Hybrid: 5 step process	Ch.7, 25a -25f/63f-63m – Draft 2025 amendment bill
4.2.2	Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Rev Hybrids	Ch.4, 16a – Draft 2025 amendment bill
4.2.3	Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules	Ch.7, 63f – Draft 2025 amendment bill
5.2.2	Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity	Ch 7, 3 – Draft 2025 amendment bill
5.3.2	Non-group owners: Partially owned Flow-through Entities	Ch 7, 6 – Draft 2025 amendment bill
5.3.5	Non-group owners: Indirect minority ownership	Ch 7, 6 – Draft 2025 amendment bill
5.4.2	Taxes allocated to a flow-through entity	Ch 7, 11/25a-25f – Draft 2025 amendment bill
5.5.2	Hybrid entities – Taxes pushed down include indirect owners	Ch 7, 64a-64h – Draft 2025 amendment bill
5.5.4	Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system	Ch 7, 64b – Draft 2025 amendment bill
5.6.2	Extension of taxes pushed down to include Reverse Hybrids	Ch 7, 64 – Draft 2025 amendment bill
6.1.4	Option to not impose top-up tax liabilities on SPVs used in securitization transactions	Ch.6, 2a-2c – Draft 2025 amendment bill
6.1.4	New definition: Securitization Entity	Ch.6, 2c – Draft 2025 amendment bill
6.1.4	New definition: Securitization Arrangement	Ch.6, 2c – Draft 2025 amendment bill

Note that Sweden’s Global Minimum Tax Act already contains a general interpretative provision which states that the provisions of the OECD Model Rules, OECD Commentary and the OECD Administrative Guidance is to be used as a source of interpretation, to the extent that these are compatible with the EU Minimum Tax Directive and EU law. As such, the Global Minimum Tax Act only needs to be amended where the June 2024 OECD Administrative Guidance means that further legislation is required.

For instance, Article 1 of the June 2024 OECD Administrative Guidance includes details provisions for determining whether or not tax has been reversed within five years under the deferred tax recapture rules in Article 4.4.4 of the OECD Model Rules. However, Sweden’s current Global Minimum Tax Act already includes deferred tax recapture rules (Chapter 3, Section 35 of the Global Minimum Tax Act) and the June 2024 OECD Administrative Guidance is focused on how to determine whether a deferred tax liability has been reversed or not. Given that the OECD Guidance is used as a source of interpretation under the Global Minimum Tax Act, these rules should apply without any specific legislative provisions being required.

Safe Harbour and Penalty Relief Guidance

Only the Transitional CbCR Safe Harbour is included in the Minimum Tax Act. The QDMTT Safe Harbour, the Transitional UTPR Safe Harbour and the NMCE Simplified Calculations are included in the December 2024 Amendment Law.

The EU QDMTT originally included in the Minimum Tax Act was removed in the amended Chapter 3, Section 39(1) of the December 2024 Amendment Law.

Elections in the OECD Model Rules

All of the elections included in the OECD Model Rules are provided in the law, including:

-Excluded Entity Election (Ch 1. 8 of the law);

-Stock-Based Compensation Election (Ch 4. 2 of the law);

-Election to use the Realization Method (Ch 4. 6 of the law);

-Election to Spread Capital Gains (Ch 4. 9 of the law);

-Consolidation Election (Ch 4. 12 of the law);

-Unclaimed Accrual Election (Ch 4. 17 of the law);

-GloBE Loss Election (Ch 4. 13 of the law);

-Prior Year Adjustment Election (Ch 4. 20 of the law);

-De minimis Election (Ch 4. 12 of the law);

-Substance-Based Income Exclusion Election (Ch 5. 11 of the law);

-Taxable Distribution Election (Ch 7. 36 of the law);

-Tax Transparency Election (Ch 7. 33 of the law);

-Distribution Tax Regime Election (Ch 7. 78 of the law).

Elections in the Administrative Guidance

The December 2024 Amendment Law includes the:

-Equity Investment Inclusion Election;

-Excess Negative Tax Carry-Forward Election;

-Debt Release Election;

-Foreign Exchange Hedge Election;

-Portfolio Shareholding Election.

Differences to Model Rules

In general, the provisions in the Swedish global minimum tax law closely follow the rules set out in the EU Global Minimum Tax Directive. However, the structure of the law is different to both the EU Directive and the GloBE Model Rules.

The differences are, therefore, minor. For instance the legislation doesn’t use the term ‘qualifying competent authority agreement’ when assessing when another group entity can file the GloBE Information Return. Instead the legislation simply uses the actual definition instead (ie bilateral or multilateral agreements that provide for the automatic exchange of annual top-up tax information returns)

Given the Swedish law is based on the EU directive, the scope of the global minimum tax also applies to domestic groups as well as international groups. As such, the definitions in the Model Rules relating to an MNE group including at least one entity or permanent establishment which is not located in the jurisdiction of the ultimate parent entity aren’t included in the Swedish law.

The Swedish law applies the UTPR via a separate additional tax. Therefore the specific requirements in the Model Rules and EU Directive that apply to UTPRs implemented as a denial of a deduction (eg Article 2.4.2) do not apply. As such, there is no equivalence to Article 2.4.2 of the OECD Model Rules in the Swedish law for the carry-forward of excess UTPR top-up tax.

Qualifying Domestic Minimum Top-Up Tax (QDMTT)

The law includes a domestic top-up tax (intended to be a QDMTT) that applies to low-taxed domestic constituent entities from December 31, 2023.

Under Chapter 6, Section 2 of the Minimum Tax Act, the domestic top-up tax is calculated based on the general GloBE calculation in the law. There are very few amendments to the general GloBE calculation and a number of aspects of the OECD Administrative Guidance (which specifically alters the general GloBE calculation for QDMTT purposes) are not reflected in the Minimum Tax Act.

However, the December 2024 Amendment Law includes updates to reflect the OECD Administrative Guidance.

Under Chapter 3, Section 6 of the Minimum Tax Act, the profits used to determine Domestic Top-up Tax could be based on an Acceptable Financial Accounting Standard permitted by an Authorised Accounting Body or an Authorised Financial Accounting Standard adjusted to prevent any Material Competitive Distortions, rather than the financial accounting standard used in the UPEs Consolidated Financial Statements.

The December 2024 Amendment Law amends Articles 6, and includes new Sections 6a-6b of Chapter 3 to apply the Local Accounting Standard rule as provided in the OECD Second Set of OECD Administrative Guidance.

As such, the QDMTT is based on the Local Financial Accounting Standard where all of the Constituent Entities located in Sweden have financial accounts based on that standard and:

1) they are required to keep or use those accounts under domestic law; or

2) the financial accounts are subject to an external financial audit.

If these conditions are not met, (or the fiscal year of the financial statements prepared on the basis of the Local Accounting Standard is different to the Fiscal Year of the Consolidated Financial Statements of the MNE Group) the UPE accounting standard or other acceptable/authorised accounting standard is used (adjusted to prevent Material Competitive Distortions if relevant).

The December 2024 Amendment law includes a new Chapter 1, Section 4b in the Minimum Tax Act to implement provisions of the Second Set of OECD Administrative Guidance which provides some specific rules relating to the currency to be used for calculating the QDMTT.

The general rule is that where all the Constituent Entities in the jurisdiction use Swedish Kroner as their functional currency, the QDMTT requires the relevant computations in that local currency.

However, if not all Constituent Entities in the jurisdiction use Swedish Kroner as their functional currency, the Filing Constituent Entity may make a Five-Year Election to undertake the QDMTT computations for all Constituent Entities in the jurisdiction either:

– in the presentation currency of the Consolidated Financial Statements; or

– in Swedish Kroner.

The OECD Administrative Guidance provides that tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules must be excluded, but this was not reflected in the Minimum Tax Act. The amended Chapter 7, Section 63 in the December 2024 Amendment law does, however, include this, along with similar provisions for taxes incurred by PEs, Hybrids and Dividend Withholding Tax (in the amended Chapter 7, Sections 64 and 25).

In order to be a QDMTT, a domestic minimum tax must apply irrespective of the shareholdings in the group entities located in Sweden. This reflects the OECD Administrative Guidance that provides that Top-up Tax that is subject to the QDMTT is based on the whole amount of the jurisdictional Top-up Tax calculated, irrespective of the ownership interests held in the Constituent Entities located in the QDMTT jurisdiction by any Parent Entity of the MNE Group.

Under the OECD Administrative Guidance, a domestic minimum tax does not need to apply to Stateless Constituent Entities to be a QDMTT. However, jurisdictions can impose a QDMTT on these entities when they are created under the domestic law of the jurisdiction.

This is included in the amended Chapter 6, Section 2 of the December 2024 Amendment Law.

If a low-taxed Swedish group entity is wholly or partly owned by a foreign parent entity, the group entity must pay the full amount of the QDMTT unless the foreign parent entity is in turn owned by one or more Swedish parent entities that directly hold all the ownership interests in the low-taxed group entity.

The UTPR exclusion for MNEs in their initial phase of international activity does not need to be included in a QDMTT, however, it can be included. The Second Set of OECD Administrative Guidance provides jurisdictions with three options regarding the temporary UTPR exclusion in their QDMTT legislation.

Option one allows the jurisdiction not to adopt it.

Option two allows the jurisdiction to adopt it but limits it to cases where no Parent Entity is required to apply a Qualified Income Inclusion Rule with respect to Constituent Entities of an MNE Group located in the QDMTT jurisdiction.

Option three allows the jurisdiction to adopt it without any limitations. (Note, if a jurisdiction opts for Option three, for the purposes of the QDMTT Safe Harbour the Switch-Over Rule would apply).

Sweden applies two one in Chapter 6, Section 16 of the December 2024 Amendment Law.

The August 2025 Draft Amendment Law includes proposed provisions for Securitisation Entities, as provided in the June 2024 OECD Administrative Guidance so that any QDMTT liability in respect of a Securitisation Entity should generally be imposed on another Constituent Entity located in the jurisdiction.

Filing & Payment

Domestic Returns

OECD Administrative Guidance

		Sweden	Sweden – Effective Dates – Draft Law
Effective Date:		Accounting periods beginning after December 31, 2023
		Section/Article	Section/Article
First Set of OECD Administrative Guidance
1.1	Rebasing monetary thresholds in the GloBE Rules	ch 1, 4
1.2	Deemed consolidation test	Ch. 2 ,6 /5a
1.3	Consolidated deferred tax amounts	Amending law, 14	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
1.4	Sovereign wealth funds and the definition of Ultimate Parent Entity	December 2024 Amending law Chapter 2, sections 14 and 32	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
1.5	Clarifying the definition of ‘Excluded Entity’	–
1.6	Meaning of ancillary for Non-Profit Organisations	Amendment law 7a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.1	Intra-group transactions accounted at cost	–
2.2	Excluded Equity Gains or Loss and hedges of investments in foreign operations	December 2024 Amending Law Chapter 4 12 a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.3	Excluded Dividends- Asymmetric treatment of dividends and distributions	December 2024 Amendment Law 9a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.4	Debt release Election	December 2024 Amending Law Chapter 4 12 b -d	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.5	Accrued Pension Expenses	ch 3, 16
2.6	Covered Taxes on deemed distributions	December 2024 Amending Law Chapter 7. 37	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.7	Excess Negative Tax Carry-forward guidance	2024 Amendment Law 37a/b/c and Chapter 4, 19a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.8	Substitute Loss carry forwards	December 2024 Amendment law, 31a-32d, chapter 3	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.9	Equity Gain or loss inclusion election	December 2024 Amendment Law Chapter 4 12 f/g	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.9	Qualified Ownership Interest/Flow through entity	December 2024 Amendment Law Chapter 4 12 h/i/j/k
2.1	Allocation of taxes arising under a Blended CFC Tax Regimes	December 2024 Amendment Law Chapter 7. 63 a – f	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.1	Application of Taxable Distribution Method Election to Insurance Investment Entities	2024 Tax Amendment Law ch 7, 36	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.2	Exclusion of Insurance Investment Entities from the definition of Intermediate Parent Entity and Partially-Owned Parent Entity	Amendment law 12/13	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.3	Restricted Tier 1 Capital		January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.4	Liabilities related to Excluded Dividends and Excluded Equity Gain or Loss from securities held on behalf of policyholders	December 2024 Amending Law Chapter 3, Section 20	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.5	Simplification for Short-term Portfolio Shareholdings	December 2024 Amendment Law Chapter 4 12 e	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.6	Application of Tax transparency election to Mutual insurance companies	2024 Tax Amendment Law ch. 7, s33	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
4.1	Deferred tax assets with respect to tax credits under Article 9.1.1	2024 Tax Amendment Law Chapter 4, Sections 25a-c	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
4.2	Applicability of Article 9.1.3 to transactions similar to asset transfers	2024 Tax Amendment Law Chapter 4, Section 28a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
4.3	Asset carrying value and deferred taxes under 9.1.3	2024 Tax Amendment Law Chapter 4, Section 28b	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
Second Set of OECD Administrative Guidance
1	Currency conversion rules	December 2024 Amending Law Ch.1, 4b	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2	MTTCs	December 2024 Amending law 29a-29f	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3	SBIE Rules
	– Foreign rules	December 2024 Amending law ch 5, 3/4	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
	Stock-based compensation election	–
	Leases	December 2024 Amending law ch 5, 4a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
	– Impairment losses inc in tangible asset value	–
4.1	QDMTT Safe Harbour	December 2024 Amending law ch 8, s 19/20	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
4.2	UTPR Safe Harbour	December 2024 Amending law ch 8, s 14	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
Third Set of OECD Administrative Guidance
1	Transitional CbCR – Purchase Accounting AdjustmentsÃƒÂƒÃ‚ÂƒÃƒÂ¢Ã‚Â€Ã‚ÂšÃƒÂƒÃ‚Â‚ÃƒÂ‚Ã‚Â (consistent reporting condition, goodwill impairment adjustment)	December 2024 Amending law Chapter 8. 6a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.2.1	Transitional CbCR – JVs
2.3.1	Transitional CbCR – Same Financial Statements/Local Financial Statements for Statutory Reporting	December 2024 Amending law ch 8, section 6	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.3.2	Transitional CbCR – Using different accounting standards	December 2024 Amending law ch 8, section 6	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.3.3	Transitional CbCR – Adjustments to Qualified Financial Statements/Dividend Mismatches	December 2024 Amending law ch 8, section 7a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.3.4	Transitional CbCR – MNEs not required to file CbC Reports	December 2024 Amending law ch 8, section 6b/18	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.3.5	Transitional CbCR – Qualified Financial Statements for PEs	December 2024 Amending law ch 8, section 6	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.4.2	Transitional CbCR – Treatment of Taxes on income of PEs, CFCs, and Hybrid Entities	December 2024 Amending law ch 8, section 4a	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
2.6	Transitional CbCR – Treatment of hybrid arbitrage arrangements	December 2024 Amending law ch 8, section 11a-g	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
3.1	Identifying Consolidated Revenue
3.2	Mismatch between Fiscal Years of the UPE and another Constituent Entity
3.3	Mismatch between Fiscal Year and Tax Year of Constituent Entity
4.2.1	Blended CFCs -multiple GloBE Jurisdictional ETRs	December 2024 Amending Law Chapter 7. 63 a – f	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
4.2.2	Blended CFCs – not required to calculate an ETR	December 2024 Amending Law Chapter 7. 63 a – f	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
4.2.3	Blended CFCs – income of non-GloBE Entities	December 2024 Amending Law Chapter 7. 63 a – f	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
5.3	30 June 2026 Filing deadline	Transitional provision to the Act (2023:880) amending the Tax Procedure Act.	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
6	NMCE Simplified Calcs	December 2024 Amending law ch 8, s 15-17	January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023
Fourth Set of OECD Administrative Guidance
1.2.1	Aggregate DTL Category basis	Applicable under general interpretative provisions
1.2.1	Exclusion of certain types of GL accounts and separate tracking	Applicable under general interpretative provisions
1.2.1	Exclusion of GL accounts that generate standalone DTAs	Applicable under general interpretative provisions
1.2.1	Exclusion of swinging accounts and separate tracking	Applicable under general interpretative provisions
1.2.2	FIFO/LIFO Basis	Applicable under general interpretative provisions
1.2.3	Aggregation of Short-term DTLs	Applicable under general interpretative provisions
1.2.2	Reversal of DTLs that accrued before the Transition Year	Applicable under general interpretative provisions
1.2.2	5 year unclaimed accrual election	Applicable under general interpretative provisions
2.1.2	Recalculated deferred tax where GloBE carrying value differs from accounting carrying value	Ch.3, 30a – Draft 2025 amendment bill
2.1.2	GloBE and accounting carrying values and the Transition Rules	Ch.3, 30a – Draft 2025 amendment bill
2.1.2	Additional provisions for Intragroup transactions accounted for at cost	Ch.3, 30a – Draft 2025 amendment bill
2.1.2	Exclusion of GloBE carrying value from SBIE	Ch.3, 30a – Draft 2025 amendment bill
3.1.3	General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps	Ch.3, 27a -27d – Draft 2025 amendment bill
3.1.3	Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income	Ch.7, 25a -25f – Draft 2025 amendment bill
3.1.3	Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries	Ch.7, 25a -25f – Draft 2025 amendment bill
4.1	Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids	Ch.3, 34c – Draft 2025 amendment bill
4.2	Allocation of deferred tax expenses and benefits from a Parent Entity to a CFC, PE Hybrid or Rev Hybrid: 5 step process	Ch.7, 25a -25f/63f-63m – Draft 2025 amendment bill
4.2.2	Five-Year Election to exclude the allocation of all deferred tax expenses and benefits to CFCs, PEs, Hybrids and Rev Hybrids	Ch.4, 16a – Draft 2025 amendment bill
4.2.3	Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules	Ch.7, 63f – Draft 2025 amendment bill
5.2.2	Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity	Ch 7, 3 – Draft 2025 amendment bill
5.3.2	Non-group owners: Partially owned Flow-through Entities	Ch 7, 6 – Draft 2025 amendment bill
5.3.5	Non-group owners: Indirect minority ownership	Ch 7, 6 – Draft 2025 amendment bill
5.4.2	Taxes allocated to a flow-through entity	Ch 7, 11/25a-25f – Draft 2025 amendment bill
5.5.2	Hybrid entities – Taxes pushed down include indirect owners	Ch 7, 64a-64h – Draft 2025 amendment bill
5.5.4	Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system	Ch 7, 64b – Draft 2025 amendment bill
5.6.2	Extension of taxes pushed down to include Reverse Hybrids	Ch 7, 64 – Draft 2025 amendment bill
6.1.4	Option to exclude a Securitization Entity from scope of QDMTT
6.1.4	Option to not impose top-up tax liabilities on SPVs used in securitization transactions	Ch.6, 2a-2c – Draft 2025 amendment bill
6.1.4	Amendments to the Switch-Off rule
6.1.4	New definition: Securitization Entity	Ch.6, 2c – Draft 2025 amendment bill
6.1.4	New definition: Securitization Arrangement	Ch.6, 2c – Draft 2025 amendment bill

January 2025 OECD Administrtive Guidance

1	Articles 8.1.4 and 8.1.5
1	Amendments to CbCR Safe Harbour for 9.1
1	Amendments to QDMTT Safe Harbour for 9.1
1	Article 9.1 of the GloBE Rules
1	Central Record of Legislation with Transitional Qualified Status

QDMTT Design

	Note	Sweden
QDMTT?(Enacted/Draft)	Is there a QDMTT in the Legislation?	Yes – Enacted
Effective Date:		Accounting periods beginning after December 31, 2023
Administrative Guidance/Safe Harbour Guidance?	Are the provisions of the OECD Administrative Guidance and Safe Harbour Guidance reflected in the current legislation?	Included in December 2024 Amendment Law.
Separate/Transposed QDMTT	Is the QDMTT a Separate QDMTT or a Transposition of the GloBE Rules (with Amendments)	Transposed
Domestic Groups	A QDMTT can also apply to purely domestic groups.	Yes
Scope Definitions	The definitions of Ultimate Parent Entity, MNE Group, and Constituent Entity correspond with the definitions in the GloBE Rules.	Included from Chapter 6, Section 15
Income and covered taxes of Constituent Entities	The QDMTT must compute the tax liability for the jurisdiction by taking into account the income and covered taxes of Constituent Entities under the GloBE Rules.	Included from Chapter 6, Section 15
Separate ETRs	A QDMTT must determine a separate ETR and Top-up Tax amount for MOCEs, Joint Ventures and JV Subsidiaries.	Included from Chapter 6, Section 15
Charging	A QDMTT must impose a Top-up Tax on one or more domestic Constituent Entities on the Excess Profits of all domestic Constituent Entities, including the domestic Parent Entity.	Included from Chapter 6, Section 15
Enforceability	The legal liability for the domestic top-up tax needs to be enforceable against at least one Constituent Entity in the jurisdiction.	Stated in Chapter 6, Section 15
Different Accounting Standard? – Optional	Is the use of a local accounting standard optional?	Under Chapter 3, Section 16 of the law, the profits used to determine Domestic Top-up Tax can be based on an Acceptable Financial Accounting Standard permitted by an Authorised Accounting Body or an Authorised Financial Accounting Standard adjusted to prevent any Material Competitive Distortions, rather than the financial accounting standard used in the UPEs Consolidated Financial Statements.
Different Accounting Standard? – Mandatory	Is the AG2 guidance followed?	The December 2024 Amendment Law amends Articles 6, and includes new Sections 6a-6b of Chapter 3 to apply the Local Accounting Standard rule
Different Accounting Standard? – Default GloBE rules	Do the general GloBE rules apply for the QDMTT accounting standard?	No
Require 100% ownership?	The QDMTT )can require 100% ownership	No
Differences to GloBE Rules: tighter restriction is consistent with local tax rules	The QDMTT can be more restrictive than the GloBE Rules where the tighter restriction is consistent with local tax rules.	None
Differences to GloBE Rules: Not relevant to in the context of its domestic tax system	The QDMTT can exclude adjustments that are not relevant to in the context of its domestic tax system.	None
Income/Loss of a PE	The QDMTT must exclude the income or loss of a foreign Permanent Establishment from the income or loss of the Main Entity.	Included from Chapter 6, Section 15
Tax Transparency	A QDMTT must include certain tax transparent provisions.	Included from Chapter 6, Section 15
Adjusted Covered Taxes Consistency	The range of taxes included in Covered Taxes needs to be the same or narrower, as under the GloBE rules.	Included from Chapter 6, Section 15
GloBE Loss Election?	Not Required in QDMTT	Included from Chapter 6, Section 15
No Pushdown to CFC or PE	A QDMTT must exclude: (1) tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules and (2) tax paid or incurred by a Main Entity that is allocated to a PE in the jurisdiction.	The amended Chapter 7, Section 63 in the December 2024 Amendment law
Exclude tax allocated to Hybrids	Second AG Guidance	The amended Chapter 7, Section 64 in the December 2024 Amendment law
Exclude allocated net basis tax on dividends (except WHT)	Second AG Guidance	The amended Chapter 7, Section 25 in the December 2024 Amendment law
UPE that is a Flow-Through Entity	Second AG Guidance	Included from Chapter 6, Section 15
UPE subject to Deductible Dividend Regime	Second AG Guidance	Included from Chapter 6, Section 15
Eligible Distribution Tax Systems	Second AG Guidance	Included from Chapter 6, Section 15
ETR Computation for Investment Entities	Second AG Guidance	Included from Chapter 6, Section 15
Investment Entity Tax Transparency Election	Second AG Guidance	Included from Chapter 6, Section 15
Taxable Distribution Method Election	Second AG Guidance	Included from Chapter 6, Section 15
Multi-Parented MNE Groups	Second AG Guidance	Included from Chapter 6, Section 15
Additional Top-Up Tax/Excess Negative Tax Expense	A QDMTT needs to have provisions for additional top-up tax where there is no Net GloBE Income and the Adjusted Covered are less than zero and less than the Expected Adjusted Covered Taxes. Amount. Excess Negative Tax Carry-forward rules also need to be in place.	Included from Chapter 6, Section 15. Excess Negative Tax C/F not Included (Before Admin Guidance).
Modified Top-Up Tax Formula	The QDMTT top-up tax formula needs to be modified as the GloBE Rules subtract tax paid under a QDMTT from the current GloBE Top-up Tax.	Included
Same Approach As GloBE Rules	A QDMTT must require that top-up tax is taken into account by the relevant Constituent Entity at the same time and in the same manner as under the GloBE Rules (eg it canÃƒÂ¢Ã‚â‚¬Ã‚â„¢t be carried forward).	Included from Chapter 6, Section 15
SBIE Included?	Not Required in QDMTT	Yes – Included from Chapter 6, Section 15
SBIE Rates same as GloBE?	Not Required in QDMTT	Included from Chapter 6, Section 15
De Minimis Rule Included?	Not Required in QDMTT	Included from Chapter 6, Section 15
Restructuring Rules?	A QDMTT needs to include restructuring rules as provided in the GloBE rules to the extent necessary to conform to the tax reorganization rules in the jurisdiction.	Included from Chapter 6, Section 15
Safe Harbours?	A QDMTT needs to contain GloBE safe harbours.	Yes, all OECD Safe Harbours
Deferred Tax Transition Rule?	A QDMTT must include the deferred tax starting point under Article 9.1.1 of the Model Rules.	Included from Chapter 6, Section 15
SBIE Transitional Rates?	Not Required in QDMTT	Included from Chapter 6, Section 15
Initial Phase of International Activity Exemption	Not Required in QDMTT	Included from Chapter 6, Section 15. Limits it to cases where no Parent Entity is required to apply a Qualified Income Inclusion Rule with respect to Constituent Entities of an MNE Group located in the QDMTT jurisdiction in the December 2024 Amendment Law.
Elections?	Where the GloBE Rules permit an election, a QDMTT must generally also provide for the election and require the MNE Group to make the same election under the QDMTT as is made under the GloBE Rules.	Yes – Included from Chapter 6, Section 15
Deferred Tax transition: First time or refreshing rule?	Second AG	None
New transition year – amend tax attributes?	Second AG	None
Currency provisions?	Second AG	Section 4b December 2024 Amendment Law
DTL Recapture rules – Aggregate DTL Categories	Fourth AG, 1.2.8
DTL Recapture rules Unclaimed Accrual Five-Year Election	Fourth AG, 1.2.8
Reverse Hybrid Pushdown	Fourth AG, 5.6.2
Securitization Entities – A QDMTT may also exclude a Securitisation Entity from its scope	Fourth AG, 6.1.4
Securitization Entities – A jurisdiction may allocate the QDMTT liability for any QDMTT top-up tax to another Constituent Entity (if any) that is located in the jurisdiction	Fourth AG, 6.1.4	Proposed – Ch.6, 2a-2c – Draft 2025 amendment bill
Note

CbCR Safe Harbour Design

	Note	Sweden
QDMTT?(Enacted/Draft)	Is there a QDMTT in the Legislation?	Yes – Enacted
Effective Date:		Accounting periods beginning after December 31, 2023
Administrative Guidance/Safe Harbour Guidance?	Are the provisions of the OECD Administrative Guidance and Safe Harbour Guidance reflected in the current legislation?	Included in December 2024 Amendment Law.
Separate/Transposed QDMTT	Is the QDMTT a Separate QDMTT or a Transposition of the GloBE Rules (with Amendments)	Transposed
Domestic Groups	A QDMTT can also apply to purely domestic groups.	Yes
Scope Definitions	The definitions of Ultimate Parent Entity, MNE Group, and Constituent Entity correspond with the definitions in the GloBE Rules.	Included from Chapter 6, Section 15
Income and covered taxes of Constituent Entities	The QDMTT must compute the tax liability for the jurisdiction by taking into account the income and covered taxes of Constituent Entities under the GloBE Rules.	Included from Chapter 6, Section 15
Separate ETRs	A QDMTT must determine a separate ETR and Top-up Tax amount for MOCEs, Joint Ventures and JV Subsidiaries.	Included from Chapter 6, Section 15
Charging	A QDMTT must impose a Top-up Tax on one or more domestic Constituent Entities on the Excess Profits of all domestic Constituent Entities, including the domestic Parent Entity.	Included from Chapter 6, Section 15
Enforceability	The legal liability for the domestic top-up tax needs to be enforceable against at least one Constituent Entity in the jurisdiction.	Stated in Chapter 6, Section 15
Different Accounting Standard? – Optional	Is the use of a local accounting standard optional?	Under Chapter 3, Section 16 of the law, the profits used to determine Domestic Top-up Tax can be based on an Acceptable Financial Accounting Standard permitted by an Authorised Accounting Body or an Authorised Financial Accounting Standard adjusted to prevent any Material Competitive Distortions, rather than the financial accounting standard used in the UPEs Consolidated Financial Statements.
Different Accounting Standard? – Mandatory	Is the AG2 guidance followed?	The December 2024 Amendment Law amends Articles 6, and includes new Sections 6a-6b of Chapter 3 to apply the Local Accounting Standard rule
Different Accounting Standard? – Default GloBE rules	Do the general GloBE rules apply for the QDMTT accounting standard?	No
Require 100% ownership?	The QDMTT )can require 100% ownership	No
Differences to GloBE Rules: tighter restriction is consistent with local tax rules	The QDMTT can be more restrictive than the GloBE Rules where the tighter restriction is consistent with local tax rules.	None
Differences to GloBE Rules: Not relevant to in the context of its domestic tax system	The QDMTT can exclude adjustments that are not relevant to in the context of its domestic tax system.	None
Income/Loss of a PE	The QDMTT must exclude the income or loss of a foreign Permanent Establishment from the income or loss of the Main Entity.	Included from Chapter 6, Section 15
Tax Transparency	A QDMTT must include certain tax transparent provisions.	Included from Chapter 6, Section 15
Adjusted Covered Taxes Consistency	The range of taxes included in Covered Taxes needs to be the same or narrower, as under the GloBE rules.	Included from Chapter 6, Section 15
GloBE Loss Election?	Not Required in QDMTT	Included from Chapter 6, Section 15
No Pushdown to CFC or PE	A QDMTT must exclude: (1) tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules and (2) tax paid or incurred by a Main Entity that is allocated to a PE in the jurisdiction.	The amended Chapter 7, Section 63 in the December 2024 Amendment law
Exclude tax allocated to Hybrids	Second AG Guidance	The amended Chapter 7, Section 64 in the December 2024 Amendment law
Exclude allocated net basis tax on dividends (except WHT)	Second AG Guidance	The amended Chapter 7, Section 25 in the December 2024 Amendment law
UPE that is a Flow-Through Entity	Second AG Guidance	Included from Chapter 6, Section 15
UPE subject to Deductible Dividend Regime	Second AG Guidance	Included from Chapter 6, Section 15
Eligible Distribution Tax Systems	Second AG Guidance	Included from Chapter 6, Section 15
ETR Computation for Investment Entities	Second AG Guidance	Included from Chapter 6, Section 15
Investment Entity Tax Transparency Election	Second AG Guidance	Included from Chapter 6, Section 15
Taxable Distribution Method Election	Second AG Guidance	Included from Chapter 6, Section 15
Multi-Parented MNE Groups	Second AG Guidance	Included from Chapter 6, Section 15
Additional Top-Up Tax/Excess Negative Tax Expense	A QDMTT needs to have provisions for additional top-up tax where there is no Net GloBE Income and the Adjusted Covered are less than zero and less than the Expected Adjusted Covered Taxes. Amount. Excess Negative Tax Carry-forward rules also need to be in place.	Included from Chapter 6, Section 15. Excess Negative Tax C/F not Included (Before Admin Guidance).
Modified Top-Up Tax Formula	The QDMTT top-up tax formula needs to be modified as the GloBE Rules subtract tax paid under a QDMTT from the current GloBE Top-up Tax.	Included
Same Approach As GloBE Rules	A QDMTT must require that top-up tax is taken into account by the relevant Constituent Entity at the same time and in the same manner as under the GloBE Rules (eg it canÃƒÂ¢Ã‚â‚¬Ã‚â„¢t be carried forward).	Included from Chapter 6, Section 15
SBIE Included?	Not Required in QDMTT	Yes – Included from Chapter 6, Section 15
SBIE Rates same as GloBE?	Not Required in QDMTT	Included from Chapter 6, Section 15
De Minimis Rule Included?	Not Required in QDMTT	Included from Chapter 6, Section 15
Restructuring Rules?	A QDMTT needs to include restructuring rules as provided in the GloBE rules to the extent necessary to conform to the tax reorganization rules in the jurisdiction.	Included from Chapter 6, Section 15
Safe Harbours?	A QDMTT needs to contain GloBE safe harbours.	Yes, all OECD Safe Harbours
Deferred Tax Transition Rule?	A QDMTT must include the deferred tax starting point under Article 9.1.1 of the Model Rules.	Included from Chapter 6, Section 15
SBIE Transitional Rates?	Not Required in QDMTT	Included from Chapter 6, Section 15
Initial Phase of International Activity Exemption	Not Required in QDMTT	Included from Chapter 6, Section 15. Limits it to cases where no Parent Entity is required to apply a Qualified Income Inclusion Rule with respect to Constituent Entities of an MNE Group located in the QDMTT jurisdiction in the December 2024 Amendment Law.
Elections?	Where the GloBE Rules permit an election, a QDMTT must generally also provide for the election and require the MNE Group to make the same election under the QDMTT as is made under the GloBE Rules.	Yes – Included from Chapter 6, Section 15
Deferred Tax transition: First time or refreshing rule?	Second AG	None
New transition year – amend tax attributes?	Second AG	None
Currency provisions?	Second AG	Section 4b December 2024 Amendment Law
DTL Recapture rules – Aggregate DTL Categories	Fourth AG, 1.2.8
DTL Recapture rules Unclaimed Accrual Five-Year Election	Fourth AG, 1.2.8
Reverse Hybrid Pushdown	Fourth AG, 5.6.2
Securitization Entities – A QDMTT may also exclude a Securitisation Entity from its scope	Fourth AG, 6.1.4
Securitization Entities – A jurisdiction may allocate the QDMTT liability for any QDMTT top-up tax to another Constituent Entity (if any) that is located in the jurisdiction	Fourth AG, 6.1.4	Proposed – Ch.6, 2a-2c – Draft 2025 amendment bill
Note

Status	Enacted Law
Law	On August 14, 2025, the Swedish Government published a draft law to amend its Global Minimum Tax Act following the March 2025 proposals. On March 20, 2025, Sweden issued proposed amendments to its Global Minimum Tax Act for consultation. The amendments are primarily to implement the OECDs June 2024 Administrative Guidance. On March 19, 2024, the Swedish Ministry of Finance published proposals, including draft legislation, to amend its GloBE law to include further aspects of the OECD Administrative Guidance. This was submitted to the Council on Legislation on August 15, 2024 and was approved by the Government on October 15, 2024. This was approved by Parliament on December 4, 2024. On December 16, 2023, the Swedish Official Gazette published Law No. SFS 2023:875, implementing the EU Minimum Tax Directive.
Effective Date	Financial years commencing after December 31, 2023 (the provisions of the December 2024 Amendment Law apply from December 31, 2024 but can be elected to apply from December 31, 2023).
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, QDMTT Safe Harbour, UTPR Safe Harbour and the NMCE Simplified Calculation Safe Harbour

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