On 24 March 2026, Finland enacted amendments to its global minimum tax rules in line with OECD Pillar Two. The law introduces updated calculations for hybrid entities, limits the use of certain deferred tax assets, and strengthens anti-avoidance rules based on GloBE guidance. It also extends filing deadlines during the transition period and clarifies rules on group structures and tax incentives. The amendments enter into force on 31 March 2026 and generally apply from financial years starting on or after 1 January 2024.
Finland’s parliament has approved amendments to its global minimum tax rules, aligning with recent OECD guidance. The changes refine rules on deferred taxes, cross-border allocations, and safe harbors, while confirming the 15% minimum tax framework. The legislation also introduces the OECD “side-by-side” approach, granting certain relief to US-based multinationals from key rules like the income inclusion rule and undertaxed profits rule. It further expands advanced rulings and introduces anti-avoidance measures. The law now awaits presidential approval.
To read more about the amendments, click here.
On November 3, 2025, Finland’s Ministry of Finance opened a public consultation on a new Bill which proposes amendments to the Act on the Minimum Tax for Large Groups to align with the OECD’s updated Global Anti-Base Erosion (GloBE) guidelines under Pillar Two. The bill explains how hybrid, investment, and securitization entities are taxed, sets rules to prevent tax avoidance schemes, and introduces advance ruling procedures starting January 1, 2026. It also explains the treatment of deferred tax assets, liabilities, and transferred assets during the transition period. The proposed rules would apply to financial years starting on or after January 1, 2024. Comments are open until November 19, 2025.