Corporate Income Tax

KPMG Sweden has a Pillar 2 team consisting of 20 people from the areas of Corporate Tax, Transfer Pricing, Accounting Advisory Services, Tax Transformation, Advisory, and Legal.  

Pillar 2 (Sw: Reglerna om tilläggsskatt) aims to ensure that large multinationals (with at least 750 MEUR in revenue) are taxed at a minimum of 15 percent, regardless of where in the world they operate. To determine whether the effective tax rate per country is at least 15 percent, each constituent entity’s numerator (Covered Taxes) and denominator (GloBE Income) must be aggregated, after being adjusted according to specific rules. During a transition period (2024-2026), a simplification rule (Transitional CbCR Safe Harbour) can be applied in some cases. This implies that full ETR calculations and full reporting may be avoided in those jurisdictions passing any of the three tests under that rule. This safe harbour rule is partly based on the country-by-country report (CbCR) but can only be applied provided that the CbCR is considered a “Qualified CbC Report”. 

To meet the requirements of the new Pillar 2 rules, both from an accounting perspective and a tax reporting perspective, a number of activities need to be carried out. Our Pillar 2 team has during the last couple of years been working with a large number of Sweden's MNEs that are covered by these rules and we know how to assist you on your Pillar 2 journey. Below are some of the most important activities we can assist you with in order for your group to become "Pillar 2 compliant". 

• Ensure that your CbC report is qualified and can be used to apply the Transitional CbCR Safe Harbour 
• Conduct or review safe harbour tests to determine which of your countries can apply simplified calculations and reporting during a transition period 
• Train employees and prepare them for upcoming Pillar 2 work 
• Conduct full ETR calculations on high risk and/or complex jurisdictions 
• Analyse your group from a Pillar 2 perspective in order to determine which entities are covered by the Pillar 2 rules and how special entities such as JVs, flow-through entities, and permanent establishments should be handled 
• Map out when and where your group will be required to register, report, and pay potential top-up tax 
• Be your speaking partner to discuss strategic decisions regarding Pillar 2, including internal processes  
• Discuss and analyse how your group can automate the upcoming data collection required in the light of your desired processes  

Don’t hesitate to reach out to us, we look forward to discuss how we can assist you on your Pillar 2 journey. 

Tax advice for non-listed companies and their owners

Within Enterprise tax, we focus on tax advice for entrepreneurial companies, growth companies, family businesses, other non-listed companies/groups, and their owners. Regardless of what phase your company is in – from start-ups to developed companies with international operations on track for listing – we can help companies and their owners with tax matters that are relevant for companies with growth ambitions in a non-listed setting.  

The tax legislation in relation to non-listed companies and their owners is often complex and also subject to continuous changes. We help you to be compliant with current tax rules and to consider upcoming changes. Our advice supports your growth at the same time as we help you to decrease the risks of negative tax consequences.  

We support you and your company in tax matters regarding:

• Corporate taxation 
• Taxation of closely held companies, entrepreneurs and the “3:12-rules” 
• Income tax returns for companies and individuals 
• Restructurings and ownership structures 
• Mergers & acquisitions  
• Incentive programs for owners and employees 
• Private equity and carried interest 
• Exit strategies and listings  

We have a team which frequently works with foreign companies starting up business in Sweden. Our goal is to raise and address all relevant matters upfront for our clients to get an efficient start in Sweden.  

Our team consists of representatives from all areas of expertise and provide full coverage of tax (CIT, TP, VAT, employer/employee taxation and immigration) and legal services. We usually start off with an introductory meeting identifying your aims and needs to provide relevant advice.   

Our services include e.g. 

• Permanent establishment (PE) analysis, i.e. to determine whether there is any Swedish taxable presence 
• Employer obligations as well as assessment of an employee’s tax liability and social security 
• Liability to pay VAT in Sweden and fixed establishment (VAT) assessment
• Registering with the Swedish Tax Agency for F-tax, as an employer and VAT
• The interaction of the obligation for a payor to deduct preliminary income tax at 30% on payments for services rendered in Sweden, F-tax registration and the liability to file specific information 
• Transfer pricing (TP), e.g. allocation of profit to a PE 
• Regular tax compliance, i.e. preparation of tax calculations, income tax returns/specific information, PAYE returns, VAT returns etc.  
• Advice on whether to register a branch or a subsidiary and assistance with this 
• Employment law 

The non-profit sector, i.e. foundations, non-profit associations and religious communities, fulfill an important function in society and are subject to complex regulations. KPMG Tax has a special group of experts with broad expertise and experience in advising the wide variety of actors in the non-profit sector. KPMG Tax collaborates with other areas of expertise within KPMG, which means that we span the entire field - civil law, income tax, VAT and accounting.

We provide advice to the non-profit sector on various issues and can help you with, among other things:    

• Assessing tax status (purpose requirement, completion requirement, business’ requirement and, for non-profit associations and religious communities, the openness requirement)   
• Assessment of taxable and tax-exempt activities and development of allocation keys between these activities (income tax and VAT)  
• Classification of independent business activities and application of the principle “unity of the supply” 
• Review and preparation of tax calculations and income tax returns   
• Assessment of VAT liability on purchases from abroad  
• Tax litigation and responding to inquiries from the Tax Agency   
• Setting up foundations   
• Support and advice in the management of foundations   
• Permutation of foundations   
• Liquidation and deregistration of foundations  

Our team is comprised of experienced advisers with special insights and knowledge of the gaming industry and work together within our KPMG’s wider Global Gaming network. With combined expertise in all areas of tax, implementation issues, regulations and compliance, AML, GDPR, and Swedish gambling legislation, our team helps ensure compliance with increasingly complex regulatory and tax issues. We accompany our gaming groups whether mature or start-up with both advisory and compliance services. 
 

KPMG Sweden can e.g. help with: 

Health check: We can help you review your business and prepare for license application process. 

Compliance Services: We can assist you with a number of regulatory services including implementation, regulatory- and conduct compliance, and gap analyses to ensure compliance with the legislation in regard to AML, GDPR, and governance. We can also provide support to already existing compliance-, AML- or internal audit functions to ease your processes of getting up to speed. 

Rationalisation of the different group entities and activities with health checks and assessments intended to keep up with developments and ensure that they remain fit for purpose. 

Ongoing advice: We can help with strategic decisions and advice on how to manage upcoming legislative changes, and key issues such as compliance and reputational risks. KPMG Sweden can also provide advice in relation to corporate tax, VAT and Transfer Pricing issues regarding challenges and opportunities specific for the industry with sustainable strategies, setting out available efficiencies such as tax consolidation and providing insight on international tax risks (e.g. WHT, PE, CFC, substance requirements, beneficial ownership etc). 

Transactional and structuring support with plans to acquire, sell, expand, merge or list 

KPMG’s litigation specialists advise and represent clients in all types of tax controversies as well as in all court and authority instances. To the benefit of our clients, we combine our extensive experience from litigation with expert insights from our colleagues specializing in other relevant fields of tax law, be it corporate tax, indirect tax, TP, individual taxation etc. Further strengthened by previous experiences from working in courts, at the Swedish Tax Agency and at law firms, we are ready to provide you with first-rate support should you be involved in any kind of tax dispute. The worldwide KPMG network makes us a reliable partner regardless of what jurisdictions your tax dispute relates to. KPMG is notably the only Big 4-firm to be ranked as Tier 1 in Tax controversy in Sweden by ITR (International Tax Review). 

Services regarding:

• Tax audits / tax investigations 
• Tax Agency investigations 
• Court litigation 
• Mutual agreement procedures (MAP) 
• Advance pricing agreements (APA) 
• Open disclosures 
• Voluntary corrections (Sw. rättelse på eget initiativ) 
• Tax payment deferrals 

You are most welcome to contact us should you have any questions regarding our services. 

In a globalized world with constantly changing tax regulations and increased demands from tax authorities, managing tax compliance on your own can be challenging. KPMG offers you the security and expertise you need to navigate this complex tax environment and achieve your business goals effectively and safely.