Menu
Trending Now
On December 10, 2025, Sweden published law No. SFS 2025:1461 in its Official Gazette. The purpose of the law is to implement the provisions of the June 2024 OECD Administrative Guidance into domestic law. This follows a draft law previously published on August 14, 2025.
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 are 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 amendments being required.
The amendments in the law will apply for tax years beginning after December 31, 2025. However, a reporting entity may choose to apply all or some of the provisions for tax years beginning after 31 December 2023.
Amendments in the December 2025 Law
| 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 – December 2025 amendment law |
| 2.1.2 | GloBE and accounting carrying values and the Transition Rules | Included in commentary |
| 2.1.2 | Additional provisions for Intragroup transactions accounted for at cost | Included in commentary |
| 2.1.2 | Exclusion of GloBE carrying value from SBIE | Included in commentary |
| 3.1.3 | General rules for allocating cross-border, current taxes under a cross-crediting corporate tax system: 4 Steps | Ch.3, 27a -27o – December 2025 amendment law |
| 3.1.3 | Specific rules for foreign PEs/CFCs, Hybrids/rev hybrids with domestic source income | Ch.3, 27d-27i – December 2025 amendment law |
| 3.1.3 | Cross-crediting between Permanent Establishments and distributions from foreign subsidiaries | Ch.3, 27d-27i – December 2025 amendment law |
| 4.1 | Extension of the Substitute Loss Carry-forward DTA to PEs, hybrids and rev hybrids | Ch.3, 34c – December 2025 amendment law |
| 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.3, 27m-27o – December 2025 amendment law |
| 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 – December 2025 amendment law |
| 4.2.3 | Exclusion of deferred tax assets or liabilities arising under a Blended CFC regime from transition rules | Ch.3, 27d-27i – December 2025 amendment law |
| 5.2.2 | Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity | Ch 7, 3 – December 2025 amendment law |
| 5.3.2 | Non-group owners: Partially owned Flow-through Entities | Ch 7, 6 – December 2025 amendment law |
| 5.3.5 | Non-group owners: Indirect minority ownership | Ch 7, 6 – December 2025 amendment law |
| 5.4.2 | Taxes allocated to a flow-through entity | Ch 3, 27a/Ch 7, 3/4/8- December 2025 amendment law |
| 5.5.2 | Hybrid entities – Taxes pushed down include indirect owners | Ch 7, 3/4/8- December 2025 amendment law |
| 5.5.4 | Hybrid entities – Entities located in jurisdictions without a Corporate Income Tax system | Included in commentary |
| 5.6.2 | Extension of taxes pushed down to include Reverse Hybrids | Ch 3, 27(5) – December 2025 amendment law |
| 6.1.4 | Option to not impose top-up tax liabilities on SPVs used in securitization transactions | Ch.6, 2a-2c – December 2025 amendment law |
| 6.1.4 | New definition: Securitization Entity | Ch.6, 2c – December 2025 amendment law |
| 6.1.4 | New definition: Securitization Arrangement | Ch.6, 2c – December 2025 amendment law |
For detailed information on the application of the GloBE Rules in Sweden, see our:
OECD Administrative Guidance: Domestic Implementation Matrix
Transitional CbCR Safe Harbour: Domestic Implementation Matrix
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2025 OECDPillars
All Rights Reserved
