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.

The new regulations are set to come into force on 1 January 2025.

The new legislation establishes provisions to define taxable persons, transactions, and economic activities subject to the rules. It specifies tax liability and outlines exemptions for certain entities, such as public bodies and non-profit organisations, as well as conditions for exempt entities and special units.

The legislation provides methods for calculating adjusted taxable results, tax costs, and additional tax amounts, incorporating deferred tax adjustments and recognising tax credits where applicable. It also introduces specific regulations for certain entities, including investment units and insurance investment units, ensuring tailored application of the tax rules.

This development aligns Sweden with the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), particularly the global effort under Pillar Two to establish a fair and consistent tax system for multinational enterprises.

Earlier, the Swedish government presented a final draft legislation to Parliament, released on 15 October 2024, which recommends amendments to its law for implementing the EU’s global minimum tax directive, including the introduction of several Pillar Two safe harbour rules.

The announcement was made in a release from the Ministry of Finance on 15 October 2024.

This proposed legislation followed the Ministry of Finance’s referral of the bill to the Council on Legislation in August to ensure that the proposals comply with the Swedish constitution and legal framework.

Key proposed changes included new regulations to ensure the Act meets international simplification standards, adjustments to how artificial arrangements are calculated, and updates to currency rules. Additionally, amendments to the Act on Settlement of Foreign Tax (1986:468) are proposed to allow offsets for foreign national additional taxes against Controlled Foreign Company (CFC) taxation and taxes on permanent establishments abroad.