The 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 seeks 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 are designed to integrate the latest administrative guidelines issued by the Inclusive Framework on 1 February, 13 July, 15 December 2023, and 24 May 2024. These guidelines, along with the OECD’s commentary, provide detailed interpretations of the model rules and address how artificial arrangements should be handled under temporary simplification rules.
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.
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.
