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CMS Expert Guide to Mastering OECD's Pillar Two in Sweden

Key stages in the introduction of global minimum taxation

Table of contents
  1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
  7. Further comments
Sweden
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

7 February 2023: issuance of a Partial Report from a governmental inquiry (SOU 2023:6), including draft legislation on the implementation of Pillar Two. 

12 October 2023: the Swedish Legislative Council (sw. Lagrådet) has commented on a draft bill from the Swedish government and brought forward certain proposals for technical changes. 

26 October 2023: issuance of a bill from the Swedish Government to the Swedish Parliament regarding legislation on the implementation of Pillar Two.

13 December 2023: planned date for the Swedish Parliament’s decision to adopt the bill regarding legislation on the implementation of Pillar Two.

14 December 2023: issuance of the Swedish Act (sw. lag [2023:875] om tilläggskatt).

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

Yes.

4. When will the Income Inclusion Rule (IIR) come into force?

2024.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

2025.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

2024.

7. Further comments

7 February 2023: the Partial Report included draft legislation on the implementation of Pillar Two.  

March 2023: the Ministry of Finance issued a memorandum containing proposed additions and clarifications to the Partial Report.