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SwedenRiksdagen

Proposed: Swedish joint ventures pay their own top-up tax

Proposition 2026/27:9 would move Swedish QDMTT liability onto the joint venture or its subsidiary itself, with registration and its own return — so foreign safe-harbour rules can apply.

By Taxxa AI OyPublished 28 October 2026

Tax

Industry: Financial and insurance activities

The government proposes that a Swedish-resident joint venture pay the whole Swedish national top-up tax amount calculated and allocated to it.Riksdagen The same would apply to a subsidiary of a joint venture.Riksdagen The venture would have to belong to a group within the top-up tax actRiksdagen, meaning a group with at least 750 million euro in annual revenue in the parent's consolidated accounts in at least two of the four financial years before the current yearRiksdagen.

Today that amount is collected from a group entity in the venture's group, not from the venture itself.Riksdagen Because liability does not sit with the venture, Swedish national top-up tax on these amounts falls outside other states' simplification rule for national top-up tax.Riksdagen The main and complementary top-up rules abroad can then apply on topRiksdagen: the full amount is taken in SwedenRiksdagen while a group entity resident elsewhere is liable for its share under those foreign rulesRiksdagen. Placing liability on the venture itself would let the foreign simplification rule applyRiksdagen and remove that double chargeRiksdagen.

The venture's tax year follows the venture's own financial year, or for a joint-venture group the parent venture's yearRiksdagen, and the same year governs the procedure. Each venture or subsidiary liable for national top-up tax would register with SkatteverketRiksdagen within 15 months after the end of the financial year in which the registration duty aroseRiksdagen. Registration exists so the administration works; a representative under chapter 5 of the procedure act is not registered instead, and the venture counts as a legal person for procedure-act purposes.

Each liable venture or subsidiary would file a tilläggsskattedeklaration.Riksdagen The return states that the filer has seen the parts of the tilläggsskatterapport it needs to complete its own returnRiksdagen, which matters because owners are often competitors and need not see the whole group report. The return is due no later than one month after the report was last dueRiksdagen; where the venture belongs to two reporting groups, one month after the later of the two report deadlinesRiksdagen. The report itself is unchanged: ventures do not file a tilläggsskatterapportRiksdagen. Skatteverket decides the tax on the return and any further investigation, may order information to check report figures, and can direct sanctions at the venture or subsidiary.

No tax surcharge is charged where the venture took reasonable steps to report correct calculations and correct assessments under the top-up rules.Riksdagen The venture itself remains liable for the full amount.Riksdagen A five-year relief and a zeroing rule for national groups are extended to ventures, apportioned per group where the venture belongs to two groups, and the direct-or-indirect ownership test for the five-year rule is clarified.

Skatteverket puts the affected population at between 20 and 40 joint ventures, with no data on sectors or sizes. The government expects no additional revenueRiksdagen: amounts are unchangedRiksdagen and only move between payersRiksdagen. The added administration is estimated very roughly at about one hour per venture, but that figure is uncertain and disputed, and advisers note shareholder-agreement, company-law and coordination work, especially with several owners and with retroactive application.

The changes would enter into force on 1 March 2027Riksdagen and apply first to financial years starting after 28 February 2027Riksdagen. Groups could elect retroactive application to financial years starting after 31 December 2023Riksdagen, with re-examination requested no later than the sixth year, registration and a simultaneous return for the ventureRiksdagen; where the return arrives at or after the three-year date for Skatteverket's notice, the agency decides and sends the notice as soon as possibleRiksdagen.

The proposal is in proposition 2026/27:9; the Riksdag decides. It sits in lagen (2023:875) om tilläggsskatt and skatteförfarandelagen (2011:1244).

Identify Swedish-resident joint ventures and their subsidiaries in groups above the 750 million euro threshold, and prepare registration and a separate top-up tax return in the venture’s own name if proposition 2026/27:9 is adopted.

Sources

Skattskyldighet för samriskföretag och deras dotterföretag