On 31 December 2018, a law was published on the implementation of CFC rules in line with EU directive (EU) 2016/1164 (2016) as adopted by the parliament which is incorporated into Finnish legislation as a Law No. 1364/2018. The law introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that qualifies as a CFC from the current 50% (direct or indirect ownership) to 25% of ownership of share capital or voting rights or profit entitlements as defined by ATAD.
The law entered into force on 1 January 2019. The law applies for the first time in the year 2019 for tax purposes.
