Sweden Issues Proposed Draft Legislation to Implement OECD Administrative Guidance

Contents

  • 30 June 2026 filing deadline
  • Currency
  • Meaning of ancillary for NPOs
  • Definition of Entity
  • Exclusion of Insurance Investment Entities
  • Transferable Tax Credits
  • QDMTT Accounting Standard
  • Excluded Dividends – Asymmetric Treatment
  • Excluded Dividends – Compound Financial Instruments
  • Substitute Loss Carry-Forwards
  • Excess Negative Tax Expense Carry-Forwards
  • Forex Hedge Election
  • Debt Releases
  • Equity Investment Inclusion Election 
  • Transitional Deferred Tax Rules
  • Transitional Rule for Asset Transfers
  • SBIE Provisions
  • Mutual Insurance Companies
  • Insurance Investment Entities and the Tax Transparency Election Blended CFC Regimes
  • QDMTT Pushdowns
  • CbCR Amendments
  • New Safe Harbours

On March 19, 2024, the Swedish Ministry of Finance issued a proposal (including Draft Legislation and Explanatory Notes) to amend its Pillar Two law to include relevant provisions of the OECD Administrative Guidance. This includes the February 2023, July 2023 and December 2023 Administrative Guidance.

Most of the legislative amendments are proposed to enter into force on January 1, 2025. However, it is proposed that MNEs can elect to apply the provisions for tax years beginning after December 31, 2023  (or, in the case of  Swedish partnerships, financial years beginning after December 31, 2023.)

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