The Swedish Tax Agency has updated its Global Minimum Tax guidance to adopt the OECD’s flexible approach for first-year GloBE Information Return filings, waiving certain exchange agreement requirements and late-filing penalties for returns due by 30 June 2026, subject to specified conditions.
The Swedish Tax Agency has updated its guidance on Global Minimum Tax (Additional Tax) obligations to reflect the OECD’s common understanding on flexible approaches for central filing of the GloBE Information Return (GIR) published on 18 May 2026.
The update provides clarification for large domestic and multinational groups subject to the Top-up Tax Act (2023:875), which implements the Pillar Two global minimum tax framework in Sweden. The legislation applies to groups with annual revenue of at least EUR 750 million in two of the previous four years and is intended to ensure a minimum effective tax rate of 15% for constituent entities located in Sweden.
Under the rules, constituent entities are generally required to submit a Top-up Tax Information Return annually. However, where certain conditions are met, the return may be filed centrally by a parent entity or another designated constituent entity, with the information subsequently exchanged between tax authorities through automatic exchange mechanisms.
The Swedish Tax Agency noted that one of the conditions for central filing is normally that an automatic exchange agreement for Top-up Tax Information Returns is in force between Sweden and the jurisdiction where the filing entity is located. Information exchanges can take place with EU Member States and with jurisdictions that have activated exchange relationships under the GIR Multilateral Competent Authority Agreement (GIR MCAA).
In line with the OECD’s 18 May guidance, Sweden has introduced temporary flexibility for Top-up Tax Information Returns due by 30 June 2026. The Tax Agency said it will, under certain conditions, disregard the requirement that an automatic information exchange agreement must already be in force for those first filings.
The relief will apply if a complete Top-up Tax Information Return has been properly submitted in a jurisdiction included on the OECD list and the Swedish Tax Agency has received notification that another entity is filing the return in a jurisdiction covered by the GIR MCAA and included on the OECD list.
Rather than requiring an active exchange agreement at the filing date, the Tax Agency will assess whether the conditions for central filing have been met after 31 December 2026, once the first exchange of information has taken place.
Where the conditions are satisfied and the return is ultimately received through the information exchange process, the Swedish Tax Agency said it will neither order the submission of a Top-up Tax Information Return in Sweden nor impose a late-filing penalty. However, if the return is not received through the exchange process, the agency may require a local filing in Sweden.
The updated guidance is intended to support the first year of GIR reporting and provide certainty for multinational groups as jurisdictions continue activating exchange relationships under the GIR MCAA.
Earlier, Sweden published amendments to its Top-up Tax Act (2023:875) in the Official Gazette (SFS 2026:305) on 31 March 2026, allowing a single resident group entity to assume responsibility for a group’s supplementary top-up tax under domestic Pillar Two rules.
