Sweden gazettes Pillar Two amendments allowing centralised top-up tax responsibility

Sweden has 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. The changes take effect starting 1 May 2026.

Sweden has 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.

Key details of the changes:

Centralised tax responsibility

If all Swedish group entities in a corporate group apply for it, the Swedish Tax Agency (Skatteverket) can decide that a single entity shall be responsible for all supplementary top-up tax allocated to the Swedish units.

• Granting of Application: The Tax Agency will typically approve this request unless there are “special reasons” to deny it.
• Adding New Entities: If a new group entity joins after this decision has been made, the Tax Agency may, upon a joint application from the responsible entity and the new member, extend the responsibility to include that new entity.

Application procedures and deadlines

• Applications must be submitted no later than 14 months after the end of the relevant tax year.
• All applications must use the specific form established by the Swedish Tax Agency.

Validity and termination

• Centralised responsibility remains in effect as long as the responsible entity is part of the group, or until the Swedish group entities jointly notify the Tax Agency that the arrangement should end.
• The Tax Agency may revoke an entity’s responsibility if there are “special reasons,” with effect either on the date of decision or a later date specified by the Agency.

The amendments aim to simplify the filing and payment of supplementary top-up tax for Swedish multinational groups under domestic Pillar Two rules.

The changes take effect on 1 May 2026.

Earlier, Sweden’s Ministry of Finance (MoF) proposed amendments to the Additional Tax Act (2023:875) to implement the side-by-side arrangement agreed by the OECD Inclusive Framework on 5 January 2026.