GloBE Country Guide: Sweden
March 17, 2023
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Sweden from January 1, 2024.
Article 2.10 of the Administrative Guidance provides more information on the treatment of the US Global Intangible Low-Taxed Income (GILTI) regime.
This is to be treated as a blended CFC Regime for GloBE purposes. Under the GloBE Rules CFC taxes are allocated to the foreign CFC (subject to the push down restriction). The GloBE Commentary doesn’t go into detail on the allocation and just provides that the CFC tax should be allocated to each CFC based on the owner’s share of the underlying income.
However, determining the allocation can be tricky when there is a blended CFC regime.
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Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Sweden from January 1, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in Switzerland from January 1, 2024.
In today’s 2023 Spring Budget, the UK government confirmed that it will include the Pillar Two Global Minimum Tax in the Spring Finance Bill 2023.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the United Kingdom from January 1, 2024.
Last week, the Vietnamese Government released Resolution 31/NQ-CP of the February 2023, Regular Government Session to speed-up Global Minimum Tax implementation.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in the Netherlands from January 1, 2024.
Analysis of the domestic implementation of the Pillar Two Global Minimum Tax rules in South Korea from January 1, 2024.
Top-up taxes under a QDMTT are added to covered taxes of a CFC but only for the purposes of calculating the allocation of Blended CFC Taxes. The way the rules operate is aimed at minimising unrelievable CFC taxes under Blended CFC Regimes. Read more.
Hungary’s Prime Minister Viktor Orbán reiterated that Hungary has an Official letter from the EU agreeing to the Local Business Tax being a covered tax for the purposes of the Pillar Two Global Minimum Tax.
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