The Swedish government has 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 follows 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 include 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.

If the draft legislation is approved, it will come into effect on 1 January 2025. A transitional provision in the Tax Procedures Act (2011:1244) is also proposed, which would waive the need for an additional tax report until 30 June 2026. The changes are set to take effect on 1 January 2025, with the option for reporting entities to apply some or all of the new provisions to tax years starting after 31 December 2023.

Earlier, Sweden’s Ministry of Finance unveiled a set of proposed amendments to the Act (2023:875) on Additional Tax, aimed at aligning with the EU Council Directive (EU) 2022/2523 on 15 August 2024. This directive seeked to establish a global minimum tax level for multinational and large national groups, based on the OECD/G20’s Inclusive Framework on Base Erosion and Profit Shifting (BEPS). The proposed updates were designed to integrate the latest administrative guidelines issued by the Inclusive Framework on 1 February, 13 July, 15 December 2023, and 24 May 2024.