Finland has opened a public consultation on proposed amendments to its Minimum Tax Act to align with the OECD/G20 Pillar 2 “side-by-side” arrangement, including new and extended safe harbours, with changes intended to apply retroactively from 1 January 2026. 

Finland’s Ministry of Finance launched a public consultation on 23 January 2026 regarding additional proposed amendments to the Minimum Tax Act, focusing on the implementation of the OECD/G20 Pillar 2 global minimum tax rules.

The consultation concerns proposed changes to the Law on Minimum Taxation on Large Groups Supplementary Tax Act and would amend the government proposal HE 196/2025, which is currently under consideration by the Finnish Parliament.

The proposed amendments reflect the side-by-side arrangement agreed by the OECD/G20 Inclusive Framework on BEPS on 5 January 2026, extension of the transitional Country-by-Country (CbCR) reporting safe harbour, and introducing a substance-based tax incentive safe harbour.

It is proposed that the amendments enter into force by 31 March 2026 and apply retroactively from 1 January 2026.

Interested stakeholders may submit comments by 4 February 2026.

Earlier, Finland’s government submitted legislative proposal HE 196/2025 to Parliament to amend the Act on the Minimum Tax for Large Groups, aligning it with OECD/G20 Inclusive Framework guidance on minimum taxation issued in 2024 and 2025.