On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and contained a general 25% EBITDA interest deduction restriction for both affiliated and non-affiliated companies party debt with a EUR 500,000 safe harbor for related party debt and a EUR 3 million safe harbor for unrelated party debt.
The new guidelines include general rules on the deductibility of interest expense, the scope of the regulation, regulated interest payments, the calculation of deductible interest expense, the reduction of non-deductible net interest expense in subsequent years, and the exception for balance sheet comparisons.
