The changes are aimed at amending the Business Income Tax Act, the Act on the Valuation of Assets in Taxation, and the Income Tax Act.
Finland’s parliament (Eduskunta) has approved Bill No. HE 125/2025 vp on 25 November 2025, introducing amendments to the Business Income Tax Act and the Valuation of Assets in Taxation Act, along with temporary changes to the Income Tax Act.
Under the proposal, the Act on the Valuation of Assets in Taxation would be amended so that, in a share exchange, shares being exchanged would be valued at their pre-exchange mathematical value when calculating the acquiring company’s net assets. This change would be limited to share exchanges between related parties. Additionally, companies would be granted the right to appeal the comparative value of their own shares.
A temporary provision would be added to the Income Tax Act to ensure that the amended rules of the Act on the Valuation of Assets in Taxation apply to all dividends distributed on or after 1 January 2026.
A new paragraph would also be added to the section of the Business Income Tax Act concerning share exchanges, specifying how the acquisition cost for the acquiring company is determined. The acquisition cost of the shares would be their aggregated pre-exchange mathematical value. This addition aligns with the proposed amendment to the Act on the Valuation of Assets in Taxation and would likewise be limited to exchanges between related parties.
Furthermore, the share exchange provisions would be extended to countries outside the European Economic Area (EEA), provided certain additional conditions are met, and the maximum cash consideration allowed would be increased.
The proposal is linked to the Government’s 2026 budget and is intended to be considered alongside it.
The acts are intended to enter into force as soon as possible.
Changes to the calculation of net assets under the Act on the Valuation of Assets in Taxation would apply from the date the law comes into effect, while changes concerning the right to appeal the comparative value would apply for the first time in taxation for the year 2025.
The amendment to the Income Tax Act would apply from 1 January 2026, and the amendments to the Business Income Tax Act would apply for the first time to share exchanges carried out on or after 1 January 2026.
