Finland’s Ministry of Finance has initiated a public consultation on 9 April 2025, on a draft proposal to Parliament to amend the regulation on the interest deduction limit.
The proposal seeks to amend the interest deduction limitation provision in the Business Income Tax Act. Under specific conditions, it would allow entities to deduct net interest expenses that are otherwise non-deductible if those expenses accrue from loans used to finance long-term infrastructure projects vital to supply chain security. The entity would have to be a critical actor as referred to in the so-called CER Directive (EU) 2022/2557 of 14 December 2022.
The proposal expands on the exemption of long-term public infrastructure projects under the Anti-Tax Avoidance Directive (ATAD). As outlined in the CER directive, entities designated as critical operators must be identified by 17 July 2026.
The law is intended to enter into force as soon as possible, taking into account the discussions with the Commission and the national implementation schedule of the CER Directive.
The consultation concludes on 30 May 2025.
