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Sweden: Proposed amendments to Pillar Two rules to implement side-by-side package

Proposed to become effective on January 1, 2027, and apply to financial years beginning after December 31, 2026

may 7, 2026

The Ministry of Finance on March 25, 2026, published a memorandum proposing targeted amendments to the Pillar Two rules to introduce new safe harbor simplification rules, including a side‑by‑side safe harbor applicable across the supplementary tax system, a dedicated ultimate parent entity (UPE) safe harbor for the top‑up tax recapture rule, and provisions on qualified substance‑based tax incentives.

In addition, the government proposes to extend the existing temporary simplification rule by one year and make technical and administrative refinements reflecting OECD/G20 Inclusive Framework guidance, with the amendments proposed to become effective on January 1, 2027, and apply to financial years beginning after December 31, 2026.

For further information, please contact a KPMG tax professional in Sweden:

Maria Barenfeld | maria.barenfeld@kpmg.se

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