Swedish Flag

GloBE Country Guide: Sweden

Summary

Status Enacted Law
Law

Government proposal — submitted 27 October 2026: Proposition 2026/27:9 would place the full allocated domestic top-up tax liability on Swedish-resident joint ventures and their Swedish-resident subsidiaries, with a local tax-return obligation. Proposed commencement is 1 March 2027, normally for years beginning after 28 February 2027. Earlier application for years beginning after 31 December 2023 requires all the relevant joint venture, subsidiaries and group constituent entities to elect. This advances the September referral; it is not enacted law or a new OECD qualification decision (bill sections 2.1–2.2 and 7).

On March 25, 2026, Sweden issues a draft law to include new Pillar Two simplification rules including the Side-by-Side Safe Harbour, UPE Safe Harbour, and other additions to Sweden’s top-up tax rules.

On August 14, 2025, the Swedish Government published a draft law to amend its Global Minimum Tax Act following the March 2025 proposals. This was published in the Official Gazette on December 10, 2025.

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 DateFinancial 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).
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursTransitional CbCR Safe Harbour, QDMTT Safe Harbour, UTPR Safe Harbour and the NMCE Simplified Calculation Safe Harbour. The SBS, UPE and SBTI Safe Harbours are included in the March 2026 Draft law.

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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