Group contributions should be excluded from profit or loss calculations in Country-by-Country (CbC) reporting.
Sweden’s tax agency (Skatteverket) has issued Position Statement No. 8-174683-2025 on 17 June 2025, clarifying its stance on group contributions in country-by-country (CbC) reporting.
According to the OECD’s May 2024 update to BEPS Action 13, group contributions should not be treated as income in CbC (Country-by-Country) reporting. These contributions, whether made or received, must be excluded from the calculation of profit or loss before tax. Additionally, any income tax paid or accrued in the CbC report should not account for taxes associated with group contributions.
Swedish companies are not taxed on a consolidated basis. However, qualifying groups (holding over 90% of capital throughout the fiscal year) can offset one company’s losses against another’s profits through group contributions, which are tax-deductible for the contributor and taxable for the recipient. EEA companies are treated as Swedish companies if the recipient is taxable in Sweden.
Sweden offers a similar deduction for cross-border group relief, allowing Swedish parent companies within the EEA to claim final losses incurred by foreign subsidiaries.
A multinational group with a Swedish parent company and annual revenue over SEK 7 billion must submit financial data for each tax jurisdiction within 12 months of the financial year’s end. Swedish entities and foreign permanent establishments (PEs) within a group are required to inform the Swedish tax agency by the end of the year about the entity responsible for submitting the country-by-country (CbC) report.
