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Sweden Considering Further Amendments to Pillar 2 Global Minimum Tax Law to Incorporate June 2024 Guidelines

24 March 2025

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Proposed Changes

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Sweden

The Swedish government has published a memorandum on draft legislation amending the Act on Additional (Supplementary) Tax, which provided for the implementation of the Pillar 2 global minimum tax in accordance with Council Directive (EU) 2022/2523 of 14 December 2022. The draft legislation amends the Act to incorporate additional administrative guidelines issued by the OECD/G20 Inclusive Framework in June 2024, offering clarifications and interpretations of the existing regulations. The amendments concern the tax liability of securitization special purpose entities, the allocation of taxes, the treatment of losses, and adjustments related to deferred taxes, hybrid entities, and the five-year rule for...