On 6 August 2018, the Finnish MoF published a draft consultation on a draft law that proposed changes to the Finnish CFC rules. The draft law aims to implement the CFC provisions contained in the EU ATAD. The bill would introduce 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. According to the draft, the new rules would enter into force on 1 January 2019 and be applied for the first time in relation to the taxation of 2019.
Related Posts

Finland proposes interest deduction relief for critical infrastructure projects
Finland’s Parliament is reviewing Government Proposal HE 227/2026 vp, part of the Government’s 2027 Budget package,
Read More
Finland: Parliament approves amending protocol to tax treaty with Switzerland
Finland’s Parliament has approved the Government Proposal HE 159/2026 vp to ratify the amending protocol to the 1991
Read More
Finland proposes investment fund tax reforms following CJEU ruling, including ELTIF changes
The Finnish Government presented Government Proposal HE 209/2026 vp to Parliament on 2 October 2026, proposing
Read More
Finland: Government proposes major reforms to corporate restructuring tax rules
Finland’s government has submitted a legislative proposal (HE 211/2026) to Parliament to amend the existing rules on
Read More
Finland proposes corporate and personal income tax cuts in 2027 Budget
Finland’s government submitted its proposal for the 2027 Budget to Parliament (HE 175/2026) on 21 September 2026. The
Read More
Finland: Government proposes lower corporate tax rate, longer loss carry-forward period from 2027
Finland's government announced, on 17 September 2026, that it proposed two significant changes to corporate taxation,
Read More