The Swedish Ministry of Finance released a memorandum proposing additional changes to the country’s Pillar Two tax rules under the Additional Tax Act (2023:875) on 20 March 2025. These amendments aim to align Sweden’s legislation with the latest administrative guidance from the OECD/G20’s Inclusive Framework on Base Erosion and Profit Shifting (BEPS).
The proposed changes address issues related to securitisation, hybrid entities, the allocation of included taxes, and the treatment of deferred tax. They are set to take effect on 1 January 2026, applying to tax years starting after 31 December 2025. However, entities may request early application for tax years beginning after 31 December 2023.
Earlier, The Swedish Official Gazette published Law No. SFS 2024:1248 on 11 December 2024, amending the Additional Tax Act to implement the Pillar Two global minimum tax into domestic law.
