Finland's Tax Administration has issued new guidance clarifying which large corporate groups fall under the country's minimum tax rules — and how their revenues must be identified, allocated, and tested against the EUR 750 million threshold that determines whether the law applies.
Finland’s Tax Administration issued detailed guidance regarding the minimum tax for large corporate groups yesterday, 9 April 2026, focusing on group identification and income allocation. This regulatory framework applies to both large domestic groups, where all entities are in Finland, and multinational groups, which have at least one entity or permanent establishment in a different jurisdiction.
Revenue thresholds and financial reporting
The Act applies to large domestic and multinational groups. A group is domestic when all its entities are located in Finland, and multinational when at least one entity or permanent establishment is located in a different jurisdiction from the group’s ultimate parent entity.
A group is considered “large” — and therefore in scope — when the consolidated annual revenues in the financial statements of the ultimate parent entity have reached at least EUR 750 million in at least two of the four fiscal years immediately preceding the year being assessed. Crucially, the current test year itself is excluded from this assessment, meaning a group always knows at the start of a fiscal year whether the rules apply to it.
A newly formed group can fall under the Act at the earliest in its third fiscal year, once it has two prior reference years in which the EUR 750 million threshold was exceeded.
Where a fiscal year is shorter or longer than 12 months, revenues must be proportionally adjusted. For example, revenues from a nine-month period are divided by 9 and multiplied by 12 to arrive at an annualised figure.
In one illustrative case, revenues of EUR 620 million over nine months equate to approximately EUR 827 million annualised — above the threshold. Conversely, EUR 850 million earned over 14 months equates to roughly EUR 729 million on an annualised basis — below the threshold.
Annual revenues for threshold purposes include all ordinary business revenues and net investment gains and losses, covering every entity consolidated line-by-line in the group’s financial statements, including exempt entities and minority-owned entities.
Group structure, exemptions, and ownership stakes
The minimum tax applies to “constituent units,” but certain entities are classified as exempt units, including government bodies, international organisations, non-profits, and pension funds.
While these units are generally outside the scope of the tax, they are still counted when determining if the group meets the overall EUR 750 million revenue threshold. The guidance also details specific ownership categories:
- Partially Owned Parent Entities (POPE): Units where more than 20% of the profit interest is held by parties outside the group.
- Joint ventures — defined as entities in which the ultimate parent holds directly or indirectly at least 50% of the ownership interest and which are consolidated using the equity method — are treated as separate group entities subject to the minimum tax rules, even though they do not satisfy the standard line-by-line consolidation test. Any resulting top-up tax is allocated to the owning groups in proportion to their interest.
- Exempt unit subsidiaries: A subsidiary is typically exempt if a primary exempt unit owns at least 95% of its value. This ownership requirement can drop to 85% if the subsidiary’s income is almost entirely comprised of specific excluded dividends or capital gains.
Impact of mergers, demergers, and digital services
Corporate restructuring can immediately alter a group’s tax status. In a merger, the combined revenues of the participating entities for the previous four years are used to check the EUR 750 million limit. Conversely, in a demerger (where a group splits into separate entities), a new group is subject to the tax if its revenue exceeds EUR 750 million in the first year following the split. If it stays below that amount in the first year, the standard “two out of four years” rule is applied thereafter.
Finally, the Tax Administration is transitioning to fully electronic communication. Starting 14 April 2026, users logging into the OmaVero portal will have “Suomi.fi messages” activated, meaning all tax-related correspondence will be delivered digitally rather than by physical mail.
Earlier, Finland gazetted Law 187/2026 of 20 March 2026, introducing several amendments to the Minimum Tax Act for Large Groups, aligning national law with European Union directives on global tax standards. The changes aligned domestic legislation with the latest guidance issued by the OECD/G20 Inclusive Framework in 2024 and 2025, ensuring ongoing compliance with the EU Minimum Tax Directive (2022/2523).
