Sweden Moves Forward on Implementation of Pillar 2 Side-by-Side Arrangement

The Swedish Ministry of Finance released draft legislation for referral to the Legislative Council on 14 August 2026, containing 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 Harbour and an Ultimate Parent Entity (UPE) Safe Harbour, as well as an extension of the transitional CbC Report Safe Harbour, and a new targeted Substance-Based Tax Incentive Safe Harbou…