The draft legislation aligns Sweden’s Top-up Tax Act with new OECD guidance and EU rules on global minimum taxation.
Sweden’s Ministry of Finance published draft legislation on 14 August 2025 to amend Act (2023:875) on top-up tax for companies in large groups. The proposal aligns Swedish rules with additional guidance issued by the OECD/G20 Inclusive Framework in June 2024 and supports implementation of the EU directive on global minimum taxation (Council Directive (EU) 2022/2523).
The draft introduces clarifications on the tax liability of securitisation special purpose entities (SSPEs), sets rules for tax allocation, outlines how losses are treated, and adjusts provisions on deferred taxes, hybrid entities, and the five-year rule for deferred tax liabilities.
If approved, the amendments will apply from 1 January 2026 for tax years beginning after 31 December 2025. Reporting entities may also choose to apply some provisions earlier, starting from tax years after 31 December 2023.
Earlier, 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.
