Swedish GloBE safe-harbour guidance published for large groups

The Tax Administration's guidance on the minimum taxation of large groups is now available in Swedish.Vero The Swedish page previously carried only a placeholder noting that the guidance was not yet available in Swedish; the complete text was published on 5 October 2026Vero. The page covers the GloBE safe-harbour rules and the transitional provision for multinational groups in the initial phase of their international activity and for large-scale domestic groups.Vero

The transitional provision in Chapter 9, Section 2 of the Minimum Tax Act (1308/2023, minimiskattelagen) reduces the Finnish national top-up tax, the income inclusion rule top-up tax on Finnish entities, and the Finnish share of the undertaxed payments rule top-up tax to zero for the first five financial periods. For a multinational group this requires the initial phase of international activity: entities in no more than six jurisdictions, and tangible assets outside the reference jurisdiction of no more than EUR 50 million in book net value. For a large-scale domestic group the only condition is that the periods are the first five in scope. A Finnish parent must still apply the income inclusion rule to low-taxed foreign entities, and the top-up tax report must still be filed on time.

The transitional country-by-country reporting safe harbour treats a jurisdiction's top-up tax as zero when one of three tests is met on the basis of the qualified CbC report and qualified accounts. The de minimis test requires revenue below EUR 10 million and pre-tax profit or loss below EUR 1 million. The simplified effective tax rate test requires a rate at least equal to the transitional rate: 15 per cent for periods beginning in 2023 and 2024, 16 per cent for 2025, and 17 per cent for 2026 and 2027. The routine-profits test requires pre-tax profit at or below the substance-based carve-out. Under Section 10, Chapter 6(4) of the Act the period covers accounting periods beginning no later than 31 December 2027 and ending no later than 30 June 2029. A group that failed every test in the preceding period cannot use the harbour again ("once out, always out"), unless it had no entities in the jurisdiction then.

The transitional undertaxed payments rule safe harbour treats the top-up tax for the ultimate parent's jurisdiction as zero for periods of at most twelve months beginning no later than 31 December 2025 and ending before 31 December 2026, where the corporate tax rate is at least 20 per cent. In practice it does not apply where the ultimate parent sits in an EU Member State applying the Directive.

Permanent harbours complete the picture. The qualified domestic top-up tax safe harbour treats the jurisdiction's top-up tax as zero where a qualified national top-up tax is computed; Finland's national tax has passed the OECD peer review. The simplified-calculations harbour for non-material entities uses simplified profit, revenue and tax figures, with zero tax where the routine-return, low-activity (average revenue below EUR 10 million, average result below EUR 1 million or a loss) or 15 per cent effective-rate test is met. The substance-based tax incentive harbour and the side-by-side parallel-model harbours apply from periods beginning 1 January 2026; under the parallel model only national top-up tax rules apply, and Finnish entities keep their Finnish filing duties.

The legal basis is the Minimum Tax Act (1308/2023), Chapters 9 and 10, implementing Council Directive (EU) 2022/2523 on a global minimum level of taxation, with OECD administrative guidance and the January 2026 Side-by-Side package taken into account through government proposals 98/2024 and 6/2026.