Legislation to take effect from 1 April 2026, with transitional rules and temporary penalty relief
The Swedish Ministry of Finance published a memorandum on 4 July 2025 proposing legislation to implement the Amending Directive to the 2011 Directive on Administrative Cooperation (2025/872) (DAC9) into national law.
The proposed law would require multinational enterprises (MNEs) and large domestic groups to file annual Top-Up Tax Information Returns, with effect from 1 April 2026.
The Swedish Tax Agency would collect and exchange relevant information with both EU Member States and non-EU countries that are parties to the OECD’s multilateral agreements. DAC9 aims to streamline filing obligations and improve the exchange of information under the Minimum Taxation Directive (2022/2523), while expanding the scope of data shared between tax authorities.
The legislation introduces rules and empowers the Swedish Tax Agency to suspend exchanges with jurisdictions that do not meet confidentiality standards. A temporary relief from administrative penalties will apply to financial years beginning before 2027 and ending no later than June 2028, provided companies acted in good faith with reasonable care.
Transitional provisions will govern reports for years ending before 31 March 2025, with exchanges to begin from December 2026 at the earliest. Public consultation is currently open, and a government bill is expected later in 2025.
Earlier, Sweden’s Ministry of Finance released a memorandum on 2 December 2024, outlining proposed changes to the Directive on Administrative Cooperation (DAC9) to streamline multinational enterprises’ tax reporting under the EU Minimum Taxation Directive (2022/2523).
