Finland’s Ministry of Finance presented the draft legislation HE 98/2024 vp to the parliament to amend the Minimum Tax Act on 20 September 2024. The Minimum Tax Act was enacted at the end 2023 to facilitate the implementation of the Pillar Two global minimum tax under Council Directive (EU) 2022/2523 of December 14, 2022.
Announced in a release, the Act is set to take effect by 31 December 2024, and will apply to financial years commencing on 1 January 2024.
Earlier, the finance ministry launched a public consultation regarding proposed amendments to the Minimum Tax Act on 12 August 2024. The bill proposes amendments to the Minimum Tax Act for large corporations.
The draft bill Draft bill HE 98/2024 vp recommends that the implementing guidelines published by the OECD and the G20’s participatory framework for 2023 be incorporated into domestic law as new tax regulations, along with clarifications on highly interpretative points. This proposal does not aim to alter the fundamental principles of the existing law. The circle, tax rates, and rules governing taxable entities would largely remain the same.
In addition, HE 98/2024 vp proposes simplifying the method for calculating the minimum tax, implementing the transitional UTPR safe harbour rules, introducing certain amendments and additions to the presumption provisions, including the presumption rule based on the country-by-country report on provisional taxation, and more.
