Under the proposal, multinational enterprise (MNE) groups would be required to submit a GloBE Information Return (GIR) through a central filing entity, usually the ultimate parent company.
The Swedish Ministry of Finance (MoF) submitted a proposal to the Legislative Council, on 13 November 2025, to introduce new rules for the automatic exchange of Top-up Tax information. The changes align Sweden’s framework with Council Directive (EU) 2025/872 (DAC9) and the OECD/G20 Inclusive Framework’s BEPS GloBE rules.
Under the proposal, multinational enterprise (MNE) groups would be required to submit a GloBE Information Return (GIR) through a central filing entity, usually the ultimate parent company. This centralised process is intended to simplify reporting for constituent entities across the EU and ensure compliance with Directive (EU) 2022/2523 on the Pillar 2 Global Minimum Tax. A standardised template and filing rules will apply.
The draft legislation sets out how exchanged information may be used, establishes confidentiality requirements, and details procedures for correcting reporting errors. It also aligns Sweden’s system with the EU DAC9 directive and the multilateral GIR-MCAA, aiming to improve the consistency and efficiency of international tax reporting.
It also provides temporary penalty relief for groups that take reasonable steps to apply the Top-up Tax rules correctly and report accurate calculations.
The measures are scheduled to take effect on 1 April 2026, with transitional rules for earlier fiscal years. First GIR filings are due by 30 June 2026, and information exchanges must be completed by 31 December 2026.
