GloBE Country Guide: Finland

Summary

Status	Enacted Law
Law	On March 10, 2025 and March 12, 2025, Finland issued explanatory guidance on the application of the Minimum Tax Act, including provisions from the OECD June 2024 Administrative Guidance relating to the DTL recapture. On August 12, 2024, the Finnish government issued draft legislation to amend its Global Minimum Tax Act to reflect aspects of the 2023 OECD Administrative Guidance. On September 19, 2024, the draft law was sent to Parliament. On December 19, 2024, the amended legislation was published in the Official Gazette. Law on the Minimum Taxation for Corporations of December 28, 2023.
Effective Date	Accounting periods beginning on or after December 31, 2023
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour. The December 2024 Amending Law includes the Transitional UTPR Safe Harbour, the QDMTT Safe Harbour and the NMCE Simplified Calculations Safe Harbour

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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