Sweden clarifies first Pillar Two filing approach: practical implications for GIR, central filing and Swedish top-up tax compliance

In May 2026, the Swedish Tax Agency (Skatteverket) updated its public guidance on Sweden’s implementation of the Pillar Two global minimum tax regime under the Additional Tax Act. Skatteverket confirms how Swedish constituent entities should approach the first wave of GloBE Information Return filing, central filing, automatic exchange and local Swedish compliance where exchange relationships may not yet be fully activated by the filing deadline.

Sweden’s first-cycle central filing position

An immediate issue for many in-scope groups is how Swedish entities should manage the first GIR filing cycle. Skatteverket states that, as a starting point, each constituent entity must annually file a top-up tax report (GIR). However, under certain conditions, the report may instead be filed centrally by the parent entity or another designated group entity for exchange with relevant jurisdictions. One condition for central filing is that there is automatic exchange of top-up tax reports between Sweden and the jurisdiction where the filing entity is located.

Skatteverket notes that the reporting entity must specify in the GIR which jurisdictions should receive which parts of the return under the OECD dissemination approach. Sweden can automatically exchange GIR information with all EU Member States and with jurisdictions for which Sweden has activated exchange under the GIR MCAA, provided the counterparty jurisdiction has also activated the relationship with Sweden.

The first-cycle issue is that some exchange relationships may not be fully activated by the local filing deadline. The OECD’s May 2026 guidance recognises this problem for the 2024 reporting fiscal year. It notes that 37 jurisdictions have implemented a QIIR and/or QDMTT applying to in-scope MNEs from their 2024 fiscal year, that GIRs for that year are due by 30 June 2026, and that relevant GIR information is expected to be exchanged by 31 December 2026 under the GIR MCAA and dissemination approach.

The OECD document provides a common understanding that implementing jurisdictions may use domestic-law mechanisms to waive penalties or refrain from enforcing local GIR filing before the exchange deadline where the GIR has been centrally filed in a listed jurisdiction by the relevant deadline and the local GIR notification has also been filed on time. The guidance also makes clear that a jurisdiction may still enforce local filing if the centrally filed GIR is not sent to it by the relevant exchange deadline. Sweden appears in the OECD annex of jurisdictions expected to be ready for central filing before 31 May 2026.

Skatteverket has now aligned its Swedish administrative position with that OECD approach for the first filings due by 30 June 2026. It states that, under certain conditions, it will disregard the requirement that an automatic exchange agreement be in force for GIRs due by that date. The two conditions are that a complete GIR has been properly filed in a jurisdiction on the OECD list, and that Skatteverket has received a notification that another entity is filing the report in a jurisdiction on the OECD list that is covered by the GIR MCAA.

Skatteverket will assess whether the conditions for central filing are met as soon as possible after 31 December 2026, following the first information exchange. Where the agency receives the report through exchange, it will not order the Swedish entity to file the GIR locally in Sweden or impose a late-filing fee. If Sweden does not receive the report through exchange, however, it may enforce local Swedish filing.

Sweden’s Pillar Two Deadlines