- Pillar 2 scope is determined by the group's consolidated revenue, not the Swedish entity's own turnover. A Swedish subsidiary with minimal revenue can be fully in scope if the group exceeds EUR 750 million across at least two of the four preceding years.
- Three separate Swedish obligations follow from being in scope: registration with Skatteverket, a GIR filing or notification, and (if applicable) a top-up tax declaration. They are separate steps with separate deadlines.
- Registration does not mean you owe top-up tax. The tax declaration is a further step, required only where the Swedish entity's effective tax rate falls below 15% and actual Swedish tax is payable.
- The group's parent can file the GIR centrally — but the Swedish entity must still register independently and file a notification. This does not happen automatically.
- For groups with a 2024 calendar-year fiscal period, registration (31 March 2026) and GIR notification (30 June 2026) deadlines have now passed. The priority is confirming compliance for that period and preparing for the 2025 period.
- Deadlines are anchored to the ultimate parent entity's fiscal year-end, not the Swedish entity's own year-end. Groups with non-calendar fiscal years will have different deadlines.
A Swedish company's own revenue is not what determines whether Pillar 2 applies to it. The relevant figure is the group's consolidated revenue at the level of the ultimate parent entity. That distinction is the one that catches subsidiary managers and local finance leads by surprise — and it is the reason a Swedish entity with a modest balance sheet can have significant compliance obligations it has not yet addressed.
A separate regime, not a replacement corporate tax rate
Pillar 2 — formally the Global Anti-Base Erosion (GloBE) rules — is the OECD's framework for ensuring large multinational groups pay a minimum effective tax rate of 15% in each jurisdiction where they operate. Sweden implemented it through Lag (2023:875) om tilläggsskatt, effective from 1 January 2024.
It is a separate layer of rules that sits alongside the standard Swedish corporate income tax regime. It does not replace Sweden's 20.6% corporate tax rate. It does not affect companies that are not part of an in-scope group. And it does not automatically result in additional tax for every entity that falls within its scope — many Swedish subsidiaries in large groups will have compliance obligations without owing any Swedish top-up tax at all.
The EUR 750 million consolidated revenue threshold is assessed at the level of the ultimate parent entity, based on the group's combined financial statements. The test must be met in at least two of the four fiscal years immediately preceding the year in question.
A Swedish subsidiary that is part of a qualifying group is a "constituent entity" regardless of its own size. The Swedish entity's local revenue, headcount, or balance sheet figures are irrelevant to the scope test. What matters is the group's position — which the local finance team may not have direct visibility of without asking the parent.
Registration, GIR, and top-up tax declaration — three steps, three deadlines
Pillar 2 creates three distinct compliance obligations for Swedish constituent entities. They are sequential in logic but operate on overlapping timelines. Understanding them separately is essential — fulfilling one does not fulfil the others.
Every in-scope Swedish constituent entity must register with the Swedish Tax Agency. This applies regardless of whether Swedish top-up tax is payable.
The Global Information Return must be filed — either by the Swedish entity itself, or by a designated group entity. If filed elsewhere, a notification must be submitted to Skatteverket.
Required only if the Swedish entity has actual top-up tax liability in Sweden — i.e., its effective tax rate falls below 15% after applying GloBE adjustments.
"We do not owe any top-up tax, so we do not need to register or file."
Registration and GIR filing (or notification) are obligations that apply to every in-scope constituent entity, regardless of tax liability. The top-up tax declaration is the step that only applies when there is actual Swedish tax to pay. Skipping registration and reporting because no tax is expected is non-compliance.
Registration: the first step that must happen regardless
GIR or notification: where most entities have choices — and conditions
Top-up tax declaration: the step most entities will not need
Calendar-year group example (fiscal year 01.01.2024 to 31.12.2024)
| Obligation | Deadline | Status (as of Oct 2026) | Note |
|---|---|---|---|
| Registration | 31 March 2026 Past | Confirm completed | Address urgently if outstanding |
| GIR or notification | 30 June 2026 Past | Confirm completed | 18-month rule for first period |
| Top-up tax declaration | 31 July 2026 Past | Confirm if applicable | Only if ETR below 15% |
| Registration (2025 period) | 31 March 2027 Upcoming | Prepare now | 15 months from 31.12.2025 |
| GIR or notification (2025 period) | 31 March 2027 Upcoming | Prepare now | 15 months — no extension for 2025 |
Deadlines for groups with non-calendar fiscal years are calculated from the ultimate parent entity's year-end using the same 15-month (or 18-month for the first period) rule. 31 December 2026 is not a universal GIR deadline — it applies only to groups whose fiscal year ends 30 September 2025.
What to verify now if you manage or advise a Swedish group entity
Pillar 2 compliance review checklist — Swedish constituent entity
Local Swedish managers often do not have Pillar 2 visibility because the analysis happens at group level. If you are responsible for a Swedish entity and have not received formal communication from the group's tax function about Pillar 2 obligations, ask specifically:
Is our Swedish entity in scope? Who is filing the GIR and from which jurisdiction? Has our Swedish registration been completed? Do we have any Swedish top-up tax liability for 2024?
These are the four questions that determine what local action is needed. Do not assume the group's central process has covered the Swedish local steps — it may not have.
Frequently asked questions
Does Pillar 2 apply to our Swedish subsidiary if our Swedish revenue is small?
Yes, potentially. The scope test uses the group's consolidated revenue, not the Swedish entity's own turnover. A Swedish entity can be fully in scope with minimal local revenue if the group as a whole meets the EUR 750 million threshold.
Can we skip the Swedish registration if our parent is filing the GIR from another country?
No. Registration is a separate Swedish obligation that applies to every in-scope constituent entity regardless of where the GIR is filed. The Swedish entity must register with Skatteverket directly. Central GIR filing does not satisfy the registration requirement.
We are a Swedish subsidiary. Our parent filed the GIR from the US. Do we need to do anything?
Yes. You still need to have registered with Skatteverket, and you still need to file a notification with Skatteverket confirming that the GIR is being filed by the US parent entity. Whether the US-Sweden automatic exchange agreement covers GloBE information returns should be confirmed with the group's tax advisors.
The deadlines for 2024 have passed. What should we do?
Confirm whether registration and the GIR or notification were completed. If they were not, take steps to regularise the position now — late compliance is preferable to continued non-compliance. Engage both the group's tax function and a local Swedish advisor familiar with Skatteverket's processes.
How can 1Office help?
1Office can assist with Pillar 2 registration with Skatteverket and with filing the notification where another group entity is submitting the GIR. For the full GIR preparation and top-up tax calculation — which require group-level financial data and specialist tax analysis — we recommend coordinating with the group's international tax advisors alongside local filing support.
Need help with Pillar 2 registration or the Skatteverket notification?
1Office Sweden assists in-scope constituent entities with registration and with the notification process where another group entity files the GIR. Get in touch to clarify what your Swedish entity needs to do.
About this article
Written by the 1Office Sweden team with reference to Skatteverket's official guidance on global minimum taxation (tilläggsskatt) and the Swedish supplementary tax law Lag (2023:875) om tilläggsskatt. This article describes the compliance framework as it applies to Swedish constituent entities and is intended to help local managers and finance leads identify the right questions to ask. It does not constitute legal or tax advice. For entity-specific analysis, engage a qualified tax advisor.
Published October 2026 · 1Office Sweden · Stockholm · [email protected]
Sources: Skatteverket — Global minimibeskattning (tilläggsskatt); Grant Thornton Sweden — Pillar 2 Registration in Sweden: Key Requirements by 31 March 2026; CMS Law — Global minimum taxation for companies in Sweden; Lag (2023:875) om tilläggsskatt (Swedish supplementary tax law).
