Auditors get final line on income tax report statement

FAR's board has adopted the final recommendation RevR 21 on the auditor's statement on the statutory income tax reportFAR, closing the consultation that opened when FAR circulated an exposure draft in June. The recommendation tells auditors what to state in the audit report and how to apply the new provisions in the Companies Act and the Auditors Act that accompany lagen (2023:340) om offentliggörande av vissa stora företags inkomstskatterapporterFAR. It will be published shortly on FAR Online.

The statement covers the preceding financial yearFAR and is given the following year in the audit reportFAR. For larger aktiebolag and handelsbolag as defined in årsredovisningslagen, the audit report must contain a statement on whether the company was obliged to publish an income tax report for the preceding financial yearFAR. Where the company was covered by the duty, the auditor must also state whether the report was actually published in accordance with the ActFAR.

The duty to make the statement is wider than the duty to prepare a report. Even where the company had no duty to prepare an income tax report, the auditor must still state whether the company fell within the rulesFAR. For smaller companies as defined in årsredovisningslagen there is no corresponding requirement, so no statement is expected in their audit reportsFAR.

A common misunderstanding the recommendation addresses is the depth of the review. Where an income tax report has been prepared, the auditor does not examine its contents in substanceFAR. The review may be limited to checking whether the report has been publishedFAR. The auditor must still go through the report far enough to establish that the document actually is an income tax report in the proper senseFAR — a published document of another kind does not satisfy the check.

The reporting duty itself catches, in essence, companies and groups with revenue above SEK 8 billion in each of the two most recent financial yearsSvenskforfattningssamling: standalone aktiebolag and handelsbolag with a permanent establishment in at least one state or tax jurisdiction other than Sweden, ultimate parent companies of groups with such a cross-border footprint, and subsidiaries of ultimate parents domiciled outside the EEA where the group exceeds the thresholdSvenskforfattningssamling. The Act implements Directive (EU) 2021/2101 on public country-by-country reportingGOV.

The rules apply for the first time to financial years beginning after 31 May 2024FAR, and the income tax report must be published no later than twelve months after the balance-sheet dateFAR. For a company with a broken financial year of 1 June to 31 May, 2024/25 is the first year coveredFAR, the report is due by 31 May 2026FAR, and the auditor's statement on that report is given in the audit report for 2025/26FAR. Auditors signing 2025/26 reports for June year-end clients are therefore the first to apply RevR 21 in practice.

Legal basis: lagen (2023:340) om offentliggörande av vissa stora företags inkomstskatterapporter with the accompanying provisions in aktiebolagslagen and revisionslagen, applied through FAR's recommendation RevR 21 Revisorns uttalande om den lagstadgade inkomstskatterapportenFAR.