Swedish Government Submits Bill in Parliament to Implement Pillar 2 Side-by-Side Arrangement

The Swedish Government has published the bill (Prop. 2026/27:4) submitted to parliament on 8 October 2026 to implement the side-by-side arrangement agreed to by the BEPS Inclusive Framework on 5 January 2026. This follows consideration of the draft legislation by the Legislative Council, which resulted in only minor editorial and language adjustments.

The submitted bill includes the Side-by-Side (SbS) Safe Harbour and the Ultimate Parent Entity (UPE) Safe Harbour, as well as an extension o…