On August 15, 2023, the Finnish Ministry of Finance issued a draft law for the implementation of the EU Global Minimum Tax Directive (the ‘EU Directive’). The draft law is subject to a consultation until September 8, 2023.
As provided in the EU Directive, the draft law includes an income inclusion rule (IIR) and an under-taxed profits rule (UTPR).
The draft law is planned to be effective from January 1, 2024, with the IIR applying to financial years beginning on after December 31, 2023. The UTPR will generally apply to financial years beginning on after December 31, 2023 (aside from where a jurisdiction opts for the delayed application of the GloBE rules under Article 50 of the EU Directive).
A domestic minimum tax (intended to be a Qualified Domestic Minimum Top-Up Tax (‘QDMTT’)) is also proposed to apply for financial years beginning on after December 31, 2023.
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