Further supplements to the regulations on supplementary tax 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 concerned further supplements to the provisions on supplementary tax for companies in large groups to implement a global minimum tax of 15 percent. S welcomes the minimum tax to stop aggressive tax planning and ensure that large companies contribute to welfare 1. S argues, however, that the process has been forced and requires a collective impact assessment to ensure that the regulatory framework does not become unreasonably burdensome for serious companies 1. M considers the supplements to be a necessary consequence of international guidelines from the OECD and G20 2. M emphasizes that the adjustments create clear liability conditions, avoid double taxation, and protect Swedish tax bases 2.
Written by AI in advance and may contain errors. The numbers lead to the speech a statement builds on; check against the text below.
Marie Olsson (S)
Mr. Speaker! This is not the first time we are discussing the law on additional tax for companies in large corporations, and it probably will not be the last time either. We have already managed to make decisions on the law. We have supplemented it once, and now we are going to supplement it once more.
The background is well-known, namely the work that has been carried out within the OECD and G20 to stop advanced tax planning through a global minimum tax level for large multinational corporations. The EU has transposed this into a directive, and in Sweden, we have implemented the directive into Swedish law through the Act on Supplementary Tax. The purpose is that the large corporations shall pay at least 15 percent effective tax calculated on a base derived from the consolidated financial statements. This may sound simple, but in reality, it is anything but simple. It concerns complicated corporate structures, different tax systems, and an international regulatory framework that is still being developed.
For us Social Democrats, the starting point is clear: Taxes shall be paid where the values are created. The tax system shall be fair, legitimate, and understandable. Companies that do the right thing should not be disadvantaged compared to those who engage in aggressive tax planning. The global minimum tax is therefore fundamentally something that we Social Democrats welcome. It is an attempt to set a lower limit for tax competition and to ensure that large global companies actually contribute to the welfare and infrastructure that they also benefit from.
It is about justice, but it is also about trust. When people out in the country – in Orsa, Dalarna and the rest of Sweden – see that they themselves pay tax on their wages, their pensions and their small businesses, they must also be able to trust that the really big ones do not get away with it. Otherwise, the trust in the entire tax system is eroded.
Mr. Speaker! The Committee on Taxation's report, Additional supplements to the provisions on supplementary tax for companies in large groups, which we are debating today, is a direct consequence of the OECD's inclusive framework adopting new administrative guidelines during 2024. In order for Swedish law to function as intended, we must adjust our rules, including when it comes to how taxes and results are distributed between different types of entities and structures.
We Social Democrats stand behind the government's proposal. It is important that Sweden lives up to the international commitments we have made and that we have a functioning regulatory framework in place. But that is not where the discussion ends. The entire process surrounding the supplementary tax has been unusually rushed. When the law was first introduced, it happened at a very rapid pace. Even then, both referral bodies and the Council on Legislation pointed out deficiencies and the need for an early review. That was also something we Social Democrats raised in connection with the work on the legislation.
Since then, we have managed to supplement the legislation with new provisions once, and now we are doing it once more. Still, we do not yet fully know how these rules work in practice for the companies covered by them. It concerns over a hundred large groups with thousands of units both in Sweden and abroad.
We view with concern that the complicated implementation process risks undermining the very purpose of the minimum tax. If serious companies that are already doing the right thing experience the regulatory framework as unreasonably burdensome while opportunities still exist for others to evade it, trust will be eroded. That is the background to our reservation. This legislation must, as the Council on Legislation states, be evaluated in the near future.
Mr. Speaker! In the reservation we have together with Vänsterpartiet and Miljöpartiet, we demand a joint impact assessment of the implementation of the law on supplementary tax. We want the government to carefully review how the regulatory framework functions, what administrative costs and practical consequences it has for the affected companies, and what simplifications are possible without us losing our grip on tax evasion. This is not an unreasonable demand. It is, on the contrary, completely reasonable when we are talking about one of the most technically advanced tax systems we have introduced in many years and when we know that practice and guidelines at an international level are still being developed.
The government parties and the Sweden Democrats content themselves in the report with saying that it is assumed that the government will carry out necessary follow-ups and analyses. We believe that it is not enough to assume that. The Riksdag should clearly request a consequence analysis. It creates better transparency, greater predictability for companies, and stronger parliamentary support for the legislation.
Mr. Speaker! The exit tax must also be placed in a larger context. The previous Social Democratic-led government pursued a purposeful work against tax evasion, aggressive tax planning, and harmful tax competition for many years. The current right-conservative government, supported by the Sverigedemokraterna, has unfortunately not shown the same perseverance. The exit tax investigation has been abandoned, the work on a modern coupon tax has been delayed, and the Swedish Tax Agency's possibilities to analyze tax errors have been weakened.
Against this background, it becomes even more important that the tools that exist, such as the law on supplementary tax which we are debating here today, function as they should. We cannot afford a situation where the regulatory framework is so complicated that it hits hard against those who try to do the right thing, while at the same time tax planners can find new loopholes.
Taxes are not just paragraphs and percentages. For the person who runs a business in a small municipality, for the person who goes to work every day, or for the person waiting for an operation in healthcare, taxes are what makes it so that there is a welfare at all. Therefore, the system must both be perceived as fair and also be fair. The supplementary tax is an important step to increase fairness between countries and between companies, but that also requires that we dare to evaluate, adjust, and simplify when needed.
We Social Democrats want a global minimum tax that works in practice, which stops advanced international tax planning and which at the same time is manageable for the companies that do the right thing. A clear, unified impact assessment is a necessary step on the way.
With that, I move for approval of the reservation from the Socialdemokraterna, Vänsterpartiet and Miljöpartiet which is found under point 2 in the report.
Adam Reuterskiöld (M)
Mr. Speaker! Today we are debating the Committee on Taxation's report number 5, Further supplements to the provisions on additional tax for companies in large groups. This is the third report in what can be called the technical trilogy resulting from the OECD's and G20's international work against the erosion of tax bases, what is commonly summarized as BEPS and Pillar 2.
Let us look at this from a slightly larger perspective. In an increasingly globalized and digitized economy, many countries have seen how profits are moved from the countries where they were actually earned to low-tax countries. This has created a distorted competition, eroded tax bases, and fueled a tax competition that no country wins in the long run. The OECD has estimated that the world loses hundreds of billions of dollars every year to this type of activity.
It is against that background that over 135 countries have agreed on a historic agreement. Pillar 2, which we are addressing today, is about large groups paying at least 15 percent in tax regardless of where in the world they have their operations. The EU has stood behind this, and Sweden has implemented it in national law.
Mr. Speaker! The legislation we are now supplementing is not something that Sweden has created in a vacuum. It is the result of continuous updates to the OECD's framework. Just like the two previous packages, this is also a necessary consequence of new guidelines that have been adopted internationally, this time in June 2024. For Sweden to have a regulatory framework that is approved internationally, we must follow this development.
The Moderates see this as an obvious part of safeguarding order and clarity in the tax system and participating fully in international cooperation against tax evasion. Sweden is a small, export-dependent country with many large, international companies, and it is therefore of utmost importance, both for Sweden and for our business sector, to have clear international rules in this area.
Mr. Speaker! I want to briefly mention what the proposal actually contains. We are making adjustments in five main areas.
Firstly: rules for special purpose entities for securitization, i.e., companies whose sole purpose is to hold assets that are securitized. Here, it is clarified who shall be liable for tax. It is about protecting creditworthiness and creating clear liability conditions.
Secondly: We are introducing a more detailed and internationally harmonized method for how included taxes shall be distributed between different group entities. It is quite technical, but the purpose is simple: to avoid double taxation, incorrect taxation, and unnecessary complications.
For the third point: We clarify how losses at fixed operating sites shall be handled. This ensures that only actual losses after offsetting affect the supplementary tax calculation. It is logical and legally secure.
For the fourth: We make necessary adjustments regarding deferred tax. Fictitious and specific deferred tax claims are treated in a manner that is consistent with the OECD's models. Again: This is about avoiding that companies are disadvantaged because accounting standards and tax legislation collide.
For the fifth: We clarify the definition of partially taxed entities. This is crucial for determining who should be taxed in a chain of ownership. Ambiguity here could have created real problems for Swedish corporations.
Mr. Speaker! The government's and the Moderates' line is clear. We shall safeguard fair competition. We shall protect Swedish tax bases without placing unnecessary burdens on companies. We shall stand up for international cooperation where the regulatory frameworks need to be the same for everyone. That is exactly what this report contributes to.
Mr. Speaker! Safeguarding tax bases is not a question of right or left. It is a question of order and about companies being able to compete on equal terms. A functioning international tax system is a fundamental prerequisite for a strong Swedish business sector and for the financing of our common welfare. The government's proposal is both necessary and well-balanced.
I vote in favor of the committee's proposal in the report.
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.