Exchange of information in supplementary tax reports and completion of the supplementary tax procedure for companies in large groups
Translated from Swedish by AI; the translation may contain errors. The Swedish text is the original.
Summary AI, written in advance
The debate concerns the exchange of information and supplements to the supplementary tax for companies in large groups. SD considers that the supplementary tax is important for fair conditions and that the legislation needs to be harmonized with international rules 1, but wants to keep the administrative burden to a minimum 2. S considers that the regulatory framework is extremely complex and requires a collective impact assessment to report administrative costs and ensure legal certainty 3 4 5. S also wants the rules to be adapted to stop tax planning with the minimum possible administrative burden 5. M argues that the supplements are necessary for clarity 6 and that it is irresponsible to redo everything 7.
Written by AI in advance and may contain errors. The numbers lead to the speech a statement builds on; check against the text below.
Eric Westroth (SD)
Mr. Speaker! Today we are debating the Committee on Taxation's report 20 concerning the exchange of information in supplementary tax reports and the completion of the procedure for supplementary tax for companies in large corporations.
Already in December 2021, the European Commission presented a proposal for a global minimum tax of 15 percent for multinational companies within the EU with a turnover of at least 750 million euro.
The proposal is based on the models that the OECD and G20 have developed. These are sometimes referred to as Pillar 2. These rules aim to counter tax base erosion and profit shifting, i.e., when companies move profits to countries with low tax levels to minimize taxation.
The EU's minimum tax directive therefore aims to ensure that large multinational corporations pay an effective tax rate of at least 15 percent on their profits, regardless of where in the world the profit was generated. It is an important measure to create fair conditions in the global market and to protect our tax bases. The directive's rules are based on consolidated financial statements and are supplemented by detailed explanations and examples developed by the OECD and the inclusive framework, of which Sweden is a part.
Mr. Speaker! In Sweden, we have already taken measures to implement the directive. On 1 January 2024, the act on additional tax for companies in large groups entered into force. This act is part of our endeavor to ensure that the global rules take effect even in our national legislation.
The supplementary tax is therefore the tax that can be levied, usually from the parent company, in cases where a company has had operations in other countries where a lower tax was paid, in order, so to speak, to top up the tax to 15 percent.
In December 2024, certain adjustments to the Act on Supplementary Tax were adopted to ensure that the regulatory framework keeps pace with international developments. In November 2025, the Act was further supplemented to ensure that it is applied correctly and follows the administrative guidelines upon which the international framework is based.
Now it is time again to adopt further supplements, while we allow the Swedish Tax Agency to automatically exchange information on data in the so-called supplementary tax reports, which will reduce the administration for both companies and the Swedish Tax Agency. At the same time, a temporary sanction relief is also introduced, which means that no tax surcharge is imposed if the company has taken reasonable measures to report correctly. It will therefore be a relief for the companies during the startup period when the rules are new and complex.
Oh, Mr. Speaker, it is a technical and complex regulatory framework. But it is also important that it is kept updated at all times. We have a responsibility to ensure that Swedish rules harmonize with other countries so that the system works in practice and does not open up for loopholes, double taxation, or unnecessary administrative burdens.
Unfortunately, however, the complexity of the regulatory framework, despite some simplification work, has increased the administrative burden, primarily for the companies. The Government has therefore emphasized that a continuous review of the regulatory framework is necessary. We must be able to adapt to new guidelines and ensure that Sweden's laws harmonize with other countries so that the system can function as intended. At the same time, the administrative burden on companies must not become too great. The work on comments and guidelines is still ongoing internationally, and we have full confidence that the Government will also in the future carry out the follow-ups and analyses that are needed.
Mr. Speaker! Ensuring a global minimum tax is a challenge but also an opportunity to strengthen confidence in our tax systems. It is a signal that we do not accept that the largest companies evade their responsibilities while ordinary citizens and smaller companies do the right thing.
I would therefore like to conclude by moving for approval of the committee's proposal for a decision.
Mathias Tegnér (S)
Mr. Speaker! Thank you, Member Westroth, for a clarifying speech! I would like to say that the Member has in a perfectly satisfactory manner accounted for this legislative process and also described the complexity that these issues actually involve.
Fundamentally, it is about two things: firstly, to ensure that tax evasion and advanced tax planning are stopped, and secondly, to secure a good business climate. We Social Democrats are confident that both are possible.
We Social Democrats have criticized the SD government for dragging its feet when it comes to tax evasion and tax fraud and for not addressing important issues. We can now also see that they are not quite prepared to take reasonable steps to safeguard the business climate. As we now talk about this legislative product, it becomes important to consider how we can ensure that it does not become more complex than necessary.
We Social Democrats have long demanded a consolidated impact assessment, precisely because of the difficult and great complexity that prevails here. Member Westroth explained it in an absolutely excellent way. The question then remains, when it is so clear how complex this is, how quickly the legislative process has gone and how difficult it will be for the companies to keep up: Why can the Sweden Democrats not envision that it is a good idea to conduct a consolidated impact assessment?
Member of Parliament Westroth says that he trusts the government and that the government shall conduct a continuous evaluation. The truth is, however, that a continuous evaluation is actually nothing.
The big question is: What are we going to do with the Riksdag? Is it not the Riksdag that should actually demand a collective impact assessment so that this law becomes as good as possible?
Eric Westroth (SD)
Mr. Speaker! Thank you for the question, Mathias Tegnér!
I can agree with the member on the merits. This work has in many respects created an administrative monster for many companies. I can, however, assure the member that work is ongoing at the government regarding this. At this stage, I do not believe that sending a motion to the government for an evaluation would add anything.
It is also true, as the member says, that the legislation has moved quickly. The international regulatory framework requires that it goes fast. Even if one were to start an evaluation now, I believe that the Committee on Taxation would be standing here debating other changes in the regulatory framework before the evaluation was complete.
This regulatory framework probably needs to be put in place in a better way before an evaluation is made. I do, in fact, agree with the member: When this has been put in place, an evaluation will be needed.
Mathias Tegnér (S)
Mr. Speaker! I thank Member Westroth for the answer.
What we Social Democrats are afraid of is that rules are now being stacked on top of each other. By that, we mean that a combined impact assessment could enable us to both see what the administrative costs will be and see if the legislation fulfills the purpose we want it to fulfill, while at the same time we also look at the possibilities for making simplifications.
We know that the legislative process went very fast when the law was introduced the first time. Parts of the terminology do not harmonize with the rest of Swedish tax legislation. Therefore, there are special reasons to conduct a consequence analysis of precisely this law.
I recall the last parliamentary term, when I sat on the Committee on Industry. Member Westroth's party colleagues then proposed impact assessments for every single piece of legislation. I was consistently skeptical of that. It is not the Riksdag's task to always demand impact analyses of every legislative product.
But if there is a legislative product, Mr. Speaker, for which we actually need to conduct a collective impact assessment, it is this one. Then I do not understand why the Sweden Democrats and the collective right do not realize that an impact assessment of these rules – which risk missing the mark and risk becoming, as the member himself said, an administrative monster for our largest companies – would be good. Why is one not prepared to take important steps to make these rules simpler for important Swedish export companies?
Eric Westroth (SD)
Mr. Speaker! It is generally the case when international organizations are to involve themselves in legislation that it does not always turn out to be so well-thought-out.
As said, the legislation regarding the supplementary tax and Pillar 2 is an ongoing work of change. It is also not a national issue. Even if we were to conduct an investigation into simplifications that need to be made, there is nothing that we can decide on nationally. It is a matter of complying with the international legislation.
Just as Mathias Tegnér, I have the ambition to keep the administrative burden for companies to an absolute minimum. In that respect, I completely agree with Member Tegnér. But I do not believe that sending a motion to the government at this stage would serve any major function. This legislation needs to be in place better before one can carry out that evaluation and come up with simplification proposals to submit to the international work on the issue.
Mathias Tegnér (S)
Mr. Speaker! We stand here once again to debate the supplementary tax, and we have actually started a little bit prematurely.
When it comes to the fact that we have debated the supplementary tax in the chamber several times, I would say that it is in itself telling. This is not a small technical adjustment in the margin made by complicated legislation, but this is part of a larger international work that is still ongoing and which still requires new supplements.
The background is known, but it is important to remind. For several years, the OECD and G20 have worked to ensure that profits are taxed where they arise and where value is created. In 2021, the model rules for global minimum taxation, which are usually called OECD's Pillar 2, were adopted, and within the EU, they were implemented through the minimum taxation directive 2022.
In Sweden, the law entered into force at the first possible opportunity on 1 January 2024. Since then, the provisions, as you all know, have been supplemented on a number of occasions. Now we stand here again and further amendments are required. The question is actually whether any legislative product has been changed so many times in such a short period.
The bill that the House is now considering concerns primarily two things. Firstly, a new system for the automatic exchange of supplementary tax reports is being introduced, and secondly, there are changes in the procedure itself. What does that mean, some might wonder. Well, the rules for reporting, orders, reviews, and certain declaration data are being changed, and a temporary sanction relief is being introduced. All of this may seem technical, but these are important issues for the companies that are actually covered by the rules.
Mr. Speaker! For us Social Democrats, the starting point has been the same the whole time. We have accepted the order, we have accepted the additional tax, because the basic idea is correct. It is right that large multinational corporations should not be able to play countries against each other. In a race to the bottom, or expressed differently, a race toward the abyss, it is right to set a lower limit for tax competition. It is right to try to ensure that the largest actors pay at least a minimum level of corporate tax. This is not a technical question, but this is a question of justice.
Previously, I have myself said that it is primarily about right being right. I still think that well summarizes what this issue is about. Ordinary wage earners, small business owners, and citizens pay their taxes every month. If they are to have confidence in the system, they must also see that the same principles that apply to them must also apply to the largest global corporations. Otherwise, the legitimacy of the system and for the open economy is eroded.
In a world where a handful of men own more than half of the world's population does combined, the question of inequality becomes extremely important, especially when we talk about the legitimacy of the tax system. In a time when the gaps are widening, when the economy and society are becoming harsher, and when ordinary households are expected to bear ever greater burdens, the question of tax justice becomes even more important. When people simultaneously see headlines about advanced tax planning – schemes in tax havens – trust is damaged; then grows the feeling that there is one system for ordinary people and another system for those with the greatest resources.
That is why the work against tax evasion is not a side issue but instead is part of the struggle for cohesion in society. It is about a society that holds together and is part of the strive towards a stronger sense of community.
Mr. Speaker! For us Social Democrats, taxation is not just about revenues in a table. Taxation is our collective financing of what people need in their everyday lives. Taxation is security in the form of police, courts, and military. Taxation is welfare in the form of school, home care, and elderly care. Taxation is industrial policy in the form of infrastructure, testbeds, and innovation systems. Taxation is community, trust, and faith in the future. That is also why taxes and competitiveness do not stand in opposition to each other. Sweden has instead become strong precisely because it has combined entrepreneurship and innovation with education, trust, functioning institutions, and stable rules of the game. That is exactly why fair taxation becomes so important. That is why the supplementary tax can help contribute to fair global rules of the game, what is also called a level playing field.
Mr. Speaker! But this only applies if the rules are introduced in a reasonable manner. This is where the decisive objection arises. That the basic idea is correct does not mean that everything is gold and green forests, but we must be able to have two thoughts in our heads at the same time. Yes, we shall combat tax evasion. Yes, Sweden shall live up to its international commitments. Yes, we shall contribute to a globally fair taxation. But we must also dare to say that the threat with this legislation is that it becomes so complicated, so heavy and so forcibly implemented that it undermines its own purpose.
With the new side-by-side solution, where Donald Trump has bullied his way to a separate solution for American companies, the risks become even greater. The worst outcome would be the following, Mr. Speaker, namely that companies that already do the right thing today get increased administrative costs, greater uncertainty, and a heavier reporting burden. At the same time, the most aggressive actors still find ways around the system. In that case, we have not strengthened fairness but only made the system more opaque for those who try to follow the rules.
This is exactly what we have warned against previously, and that is also why we have repeatedly demanded a comprehensive impact assessment of this legislation.
Mr. Speaker! The bill before us shows that the complexity of the rules is extremely high. The supplementary tax report that companies are to submit contains extensive information on group structure, calculations of effective tax in each state where they have operations, and the distribution of any supplementary tax. The reporting can be submitted in one state, which is positive, and thereafter be exchanged between tax authorities in different countries. As I mentioned earlier, new rules are added regarding orders, review periods, confidentiality, usage restrictions, and the temporary sanction relief.
But just the fact that another supplementary bill is now needed shows that we are not finished with the legislation. That is exactly why we Social Democrats think the government's position is so strange. It is said that the consequences for companies of the individual proposals are limited. At the same time, it is admitted that it concerns an extensive and complex regulatory framework. I believe that Member Westroth a moment ago called it an administrative monster.
This is a multi-year international effort that is also still being developed. If things do not end up in the right place at the right time, there is a risk that the rules will not be expedient. Therefore, we Social Democrats believe that it is not enough to hope for future follow-ups from the government. We believe that the government must instead be required to report what the regulatory framework actually costs, how it works in practice, and what simplifications are possible.
Our reservation is reasonable and balanced, I mean. We stand behind the changes now proposed in the bill, as they were needed to adapt Swedish law to international agreements. But we also say that the implementation has been marred by problems, that the pace has been forced, and that there is a real risk that the regulatory framework will become unreasonably burdensome for the companies that already do the right thing today. It is therefore that we want a comprehensive impact assessment with an accounting of administrative costs and an investigation of possible simplifications.
Mr. Speaker! This is, therefore, not a no to international cooperation – on the contrary. It is truly not a no to the fight against tax evasion. We mean, as said, that it is the SD government that is dragging its feet and is slow-moving in this area. This is also not a no to a global minimum taxation as a principle. But we demand order and clarity, an implementation that works, and an evaluation of the consequences. Thus, our proposal becomes a yes to justice, a yes to large companies doing the right thing, and at the same time a yes to legal certainty, predictability, and reasonableness.
If this legislation is to hold over time, it must also be perceived as legitimate. And legitimacy is not achieved by stacking new rules on top of old ones, like blocks in a playroom, while crossing your fingers that the tower doesn't collapse. Legitimacy is created if we legislators find out what consequences the rules we decide on will have and take responsibility for them. Legitimacy is achieved by ensuring that the law hits the mark, stops advanced tax planning, and at the same time does not shift the costs onto the well-managed companies. That is where, and nowhere else, the dividing line lies in today's debate.
Mr. Speaker! With that, I move for approval of the committee's proposal under point 1 and approval of the reservation under point 2.
Adam Reuterskiöld (M)
Mr. Speaker! Today we are debating the Committee on Taxation's report number 20, concerning the exchange of information in supplementary tax reports and the supplementation of the regulatory framework for supplementary tax for large corporations. It is, as many have pointed out previously, complex and technically advanced material. But behind the technology lies a very clear political core: fair conditions, functioning competition, and a tax system that people and companies can rely on. Let me start there.
Sweden shall be a country where it pays to work, invest and run businesses. We shall have a business climate that attracts investors and creates new jobs. But we shall also be able to have tax rules that are fair and predictable. They are not opposites. They are two sides of the same coin. Without fair rules, trust is eroded. Without good conditions, growth is eroded.
Mr. Speaker! For a long time, we have seen that large multinational corporations have been able to use differences between countries' various tax systems to reduce their taxation. It has had consequences. It has distorted competition. Smaller and more locally active companies, which do not have the same opportunities for advanced tax planning, have had to bear a greater burden. It has eroded tax bases, and it has ultimately affected confidence in the entire tax system.
It is against that background that the international cooperation on minimum taxation has emerged. Sweden participates in it, and it is fundamentally good. But it also places demands on how we implement the regulatory framework nationally.
Mr. Speaker! The report we are now considering is not about introducing new tax rules or raising tax levels. It is about getting an already decided system to work in practice. It aims to create clarity, legal certainty, and efficient exchange between countries. It is crucial. Without functioning information exchange, the regulatory framework risks becoming ineffective. In the worst case, it risks creating uncertainty for companies that want to do the right thing but do not receive clear instructions or end up caught between different countries' regulatory frameworks.
Through the supplements now proposed, the possibilities to handle the supplementary tax in a correct manner are strengthened. It gives authorities better conditions to work effectively, and it gives the companies clearer rules of the game.
Mr. Speaker! A central objection from the opposition, as we heard earlier, is that there is a lack of sufficient impact assessment. It is a serious objection, and therefore it deserves a clear answer.
Firstly: We are dealing with a regulatory framework that is fundamentally internationally developed and negotiated. The structure, principles, and scope are already established through international agreements. The room for maneuver nationally is largely about how we implement and complement this.
Secondly: The supplements we are now dealing with are precisely supplements, not an entirely new system. They aim to ensure that the exchange of information works and that the application is legally secure. To demand a comprehensive impact assessment of the entire system in that situation would be misleading. What we are doing here is to adjust and improve the functionality within an already decided framework.
Thirdly: The alternative to implementing these additions is not a neutral zero position. The alternative is a less functional system, a system that fails in the exchange of information and increases uncertainty and risks. It entails a risk of both double taxation and tax evasion.
Mr. Speaker! The Moderates argue that responsible politics is about weighing different risks against each other. In this case, it is clear that the risks of not acting are greater than the risks of implementing the proposed additions.
We get a more robust system. We get clearer rules. And we ensure that Sweden lives up to its international commitments in a way that also safeguards the competitiveness of Swedish companies. It is reasonably and responsibly balanced.
Mr. Speaker! For us, it is important to emphasize what this is not. It is not a proposal that in itself increases the tax burden for Swedish companies. It is not a proposal that aims to make it harder to run businesses in Sweden. It is, on the contrary, about creating order and clarity in a complex international system. And precisely order and clarity are crucial for competitiveness. Companies do not only demand low taxes. They also demand stable, predictable, and fair rules.
We Moderates want to see more companies growing in Sweden. We want to see more investments, more innovation and more jobs. Then we must ensure that the rules of the game are the same for everyone. The proposal in this report contributes to just that. It reduces the risk that certain actors can acquire competitive advantages by exploiting systemic differences. It strengthens the legitimacy of taxation. And it makes it easier for serious companies to do the right thing.
Mr. Speaker! It is natural that there are different opinions in matters that are so technically advanced. But the committee's assessment is clear: the Government's proposal is expedient and should be implemented.
To abstain would mean increased uncertainty, poorer functionality and a weak system in the fight against tax evasion. It would not be responsible.
Sweden shall be a strong voice for free markets and entrepreneurship. But we shall also stand up for fair conditions and a tax system that holds over time. This report is a step in the right direction.
I therefore move for approval of the committee's proposal and rejection of the motions.
Mathias Tegnér (S)
Mr. Speaker! I thank Member Reuterskiöld for the speech. Fundamentally, I believe we agree on much. We agree that it is important to have a good business climate. We may sometimes differ slightly on how to achieve it. We are usually in agreement that there should be clear and well-defined rules that create predictability. In area after area, we agree on how the regulatory structures should look. Sometimes we may disagree on things such as tax levels and what the taxes should be used for.
What I might have had objections to in the member's speech was that the listener could sense and possibly believe that there are parties here in the Riksdag that are opposed to implementing the bill. I want to be clear that we Social Democrats have stood behind the bill, because it implements a number of changes that make this legislative complex easier to implement – if the effects become what we intended. Uncertainty regarding the latter is one of the reasons why we have demanded a consequence analysis.
Member Reuterskiöld noted that what we are making decisions on now is not the entire legislation but only a part of it. That is quite correct. But I would then like to remind the audience and also Member Reuterskiöld that we Social Democrats proposed a consequence analysis both at the first decision on the rules and when the latest adjustment was made. Because the legislative process has been rushed and furthermore occurred in a different way than what is customary, there are reasons to carry out a consequence analysis of the regulatory frameworks to ensure that they do not become more complicated than necessary. The question is why the Moderaterna are against this proposal.
Adam Reuterskiöld (M)
Mr. Speaker! I thank Member Tegnér for the question. It was not entirely unexpected, given the previous debate in the rearview mirror.
It is naturally important to be clear about what we are deciding on. It is not the regulatory framework as a whole that we are deciding on, but this is a supplement. To demand a systematic and thorough analysis of how it would function in reality in that situation is perhaps not quite reasonable, and this is also not the best way to do it.
These additions need to be made, and we take responsibility for carrying them out. Then, a piece of legislation is not a final product, especially not when it is developed internationally. It will naturally have an impact.
One can wonder – and perhaps those listeners who are not involved in politics do – why the member in this situation, when we are making a supplement to an already existing legislation, is so strongly focused on precisely the impact assessment. It may be because we are fundamentally actually in agreement on the legislation, as member Tegnér also pointed out. We are, therefore, not in disagreement about the purpose of the system. We are not in disagreement that it should be introduced. None of us think that this is fundamentally negative for Swedish companies. And it is, therefore, a question of a supplement.
We also have to take into account that this is an international agreement. It will naturally not be optimal for every individual country – that is in the nature of the matter. I think that this should be implemented. I also think, in line with what previous speakers have stated, that it should be reviewed continuously to see how it works in reality.
Mathias Tegnér (S)
Mr. Speaker! For the first point: Are we in disagreement about the regulatory framework? No, we are not. We agree that this type of regulation is needed. There is no doubt about that.
Secondly: Why do we Social Democrats want to carry out a consequence analysis of the regulatory framework now? I want to remind Member Reuterskiöld that we have proposed a consequence analysis at every opportunity, precisely because it has been an exceptional legislative process where terminology that has not existed in our tax legislation previously has also been introduced. It is, therefore, an exceptional situation that requires exceptional measures.
The answer to the question why we are proposing a consequence analysis again is that we want to give you a new chance, Adam Reuterskiöld. You did not take the chance the first time. You did not take the chance the second time. Now you get a third chance. Vote in favor of a consequence analysis to ensure that these rules are introduced in the best possible way!
These rules will come to Swedish legislation via the EU's minimum tax directive. This gives us in Sweden an opportunity to adapt them to the laws we already have. The lines of thought and patterns of thinking from these agreements need to be introduced into Swedish law. But there is an opportunity to do it in different ways. We Social Democrats have noted that it must be done in a way that both puts a stop to advanced tax planning and ensures that the administrative burden for companies becomes as small as possible.
Now we give you another chance. We have given you a first chance. We have given you a second chance. Now we give you a third chance to review the legislation and conduct a consequence analysis, so that both of these requirements are met: Stop the tax planning, and do it in a way that is as good as possible for the companies! In that case, it is the member who will be held responsible. Why are you against a consequence analysis that could make the legislation better for Sweden's companies?
Adam Reuterskiöld (M)
Mr. Speaker! The tone in Mathias Tegnér's argumentation and polemic is high, considering that we are actually talking about supplementing existing legislation. To say "halfway – we retreat and redo everything" in this situation would be irresponsible. It would also be directly negative for how we are perceived internationally. This is not just EU legislation but international legislation that is greater than that.
It is interesting to hear how the polemic recurs but in the opposite way. During the previous parliamentary term, the member and the Socialdemokraterna constantly emphasized the unnecessary nature of conducting continuous impact assessments, so I understand that this is also politics. But to say in this situation that we are going to tear everything up and conduct an impact assessment would be irresponsible, and that is also what the preparation provides.
The deliberation was hereby concluded.
Source: The Swedish Parliament. The speeches come from the open data of the Riksdag, translated into English by AI, which may contain errors.