On 15 August 2023, the Finnish Ministry of Finance initiated a consultation regarding Draft Bill No. VM036:00/2023, which aims to implement the Pillar 2 global minimum tax in alignment with Council Directive (EU) 2022/2523. This bill includes the introduction of two key provisions: the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR). These provisions are intended to establish a minimum tax rate of 15% for multinational enterprise (MNE) groups that have earned annual consolidated revenues of at least EUR 750 million in at least two of the preceding four fiscal years.
Additionally, the bill includes the introduction of a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups, referred to as a domestic supplemental tax in Finland. The IIR and QDMTT provisions are set to be applicable for financial periods commencing on or after 31 December 2023, while the UTPR provision will take effect for financial periods commencing on or after 31 December 2024. Comments are invited by 8 September 2023.