Sweden Implementing Pillar 2 Side-by-Side Arrangement

The Swedish Ministry of Finance has announced proposed amendments to the Additional Tax Act to implement the side-by-side arrangement agreed to by the BEPS Inclusive Framework on 5 January 2026. This includes a Side-by-Side (SbS) Safe Harbor and an Ultimate Parent Entity (UPE) Safe Harbor, as well as an extension of the transitional CbC Report Safe Harbor, and a new targeted Substance-Based Tax Incentive Safe Harbor. It is also proposed to supplement the provisions on deferred tax expense wh…