Pillar 2: Registration requirements for Swedish Constituent Entities by 31 March 2026

Overview of Pillar 2

The global minimum tax, Pillar 2, is not just yet another regulatory change. The framework is extensive and has a direct impact on how multinational groups govern, report and ensure tax compliance.

As the rules are now being implemented in a large number of countries, they aim to increase transparency and establish a minimum effective tax rate of 15 percent. In Sweden, the Swedish Tax Agency is responsible for coordinating registration, information exchange and the reporting made under the new legislation. 2026 marks the first year of practical application.

Many companies are now in a position where they must both interpret international guidelines and act in accordance with the Swedish requirements, including new digital filing systems, reporting formats, and deadlines. This places high demands on governance, data quality, and clear internal accountability, far beyond merely fulfilling a new filing requirement.

“Pillar 2 is more than a set of rules. It is a stress test of groups’ abilities to manage complex financial information, coordinate across jurisdictions, and ensure that decision‑making is robust, even as the regulatory frameworks evolve in real time,” says Henrik Hedberg, Tax Partner at Grant Thornton.

Which entities must register under Pillar 2?

Pillar 2 applies, in simplified terms, to companies (constituent entities) being part of groups with revenues exceeding EUR 750 million. This means that many Swedish subsidiaries in international medium‑sized and large groups fall within scope.

The purpose of the Top‑up Tax Act is to ensure a global minimum tax and requires an annual filing with the Swedish Tax Agency. The information is subsequently exchanged between Sweden and other relevant jurisdictions.

Are you unsure whether your group is in scope? Our tax specialists can assist with an assessment.

Registration and reporting obligations

The process consists of three main stages:

1. Registration with the Swedish Tax Agency
2. Filing of the Global Information Return (“GIR”), or submission of a notification that another entity will file the GIR
3. Filing of the Top‑up Tax Return, if the company is liable to pay top‑up tax in Sweden

All steps are completed digitally via the Swedish Tax Agency’s e-services.

Digital services provided by the Swedish Tax Agency for Pillar 2

The Swedish Tax Agency has launched, and plans to expand, a set of e-services for Pillar 2, including:

• Registration
• Filing of the GIR
• Notification that another entity will file the GIR
• Filing of Top-up Tax Returns

Registration and notifications may be submitted by a designated individual with Swedish e‑identification. However, filings of the GIR and the Top‑up Tax Return are expected only for authorised signatories or persons with equivalent authority.

The e-services made available to date are accessible in English.

Key Pillar 2 dates in Sweden

The registration and reporting obligations follow the ultimate parent entity’s financial year according to the consolidated financial statements. Here you find a summary of the key timelines for companies that use the calendar year 2024 as their financial year, and fiscal year, the first year of legislative application.

1. Registration no later than 31 March 2026

Swedish constituent entities must register within 15 months after the end of the fiscal year.

For groups following the calendar year, the registration should be made no later than 31 March 2026. The e-service for registration is now open.

2. Global Information Return no later than 30 June 2026

All entities in scope of Pillar 2 must file a GIR in XML format in accordance with the OECD standards. An exception applies where another entity, for example the ultimate parent entity, files the report, and Sweden has an automatic exchange‑of‑information agreement with the relevant jurisdiction. This must then be notified to the Swedish Tax Agency.

The filing or notification must be submitted no later than 30 June 2026. The notification e-service is open, whereas the filing e-service will open during spring 2026.

3. Top‑up Tax Return no later than 31 July 2026

This obligation applies only if the company is liable to pay top‑up tax in Sweden. The Top‑up Tax Return must be filed no later than one month after the GIR deadline, i.e. 31 July 2026. The e-service will open in May 2026.

Checklist: Key steps to ensure compliance with the Top‑up Tax Act

1. Determine whether the constituent entity is in scope of Pillar 2.
2. Register the company via the Swedish Tax Agency’s e-service by 31 March 2026.
3. Determine whether the company must file the GIR or whether another group entity will do so.
4. File the GIR or submit the notification by 30 June 2026.
5. Assess whether the entity must file a Top‑up Tax Return.
6. File the Top‑up Tax Return by 31 July 2026 if top‑up tax should be paid.

How Grant Thornton can assist

We support you throughout the entire Pillar 2 process, from determining whether and how the rules apply to your group, to ensuring correct registration, reporting and international compliance. Our advisors help you:

• Determine whether the group is within scope of Pillar 2 and the practical implications for your Swedish entities.
• Navigate the registration process, including required information and correct sequencing of notifications.
• Manage reporting obligations, both in Sweden and in other relevant jurisdictions through our global network, from GIR filings in the OECD XML format to ongoing compliance.
• Analyse and calculate top‑up tax, including safe harbour assessments and other critical technical considerations.
• Interpret and apply the rules correctly, based on Swedish legislation, the EU Directive and OECD Model Rules.

Want to know more regarding how Pillar 2 affects your group? Contact us, we are here to help you act timely.

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