Finland plans to amend its Minimum Tax for Large Groups to align with 2024–2025 OECD and G20 guidance, introduce an anti-avoidance rule, and allow advance rulings, with changes applying from 2024 and the new anti-avoidance provision from 2027.
Finland’s government has presented a legislative proposal (HE 196/2025) to parliament (published on 2 January 2026), which seeks to amend the Act on the Minimum Tax for Large Groups (1308/2023) to incorporate the OECD and G20 Inclusive Framework guidance on minimum taxation issued in 2024 and 2025.
The Act also seeks to enable the Tax Administration’s advance ruling procedure in certain cases and to introduce a general anti-avoidance provision on the minimum tax into national law.
The Act is based on Council Directive (EU) 2022/2523, which establishes a global minimum tax for multinational and large domestic groups. Alignment with the Inclusive Framework’s Pillar 2 interpretations is essential for domestic rules to be recognised internationally as qualifying rules.
To achieve this, the proposal enacts into Finnish law new tax rules and key clarifications from the 2024–2025 OECD and G20 guidance, while other interpretative clarifications would be addressed through alternative means. The proposal does not change the law’s core principles, including the taxpayer base, tax rates, or tax rules.
The amendments are expected to take effect by the end of March 2026 and will apply to financial periods beginning on or after 1 January 2024, except for the new anti-avoidance rule, which will apply from 1 January 2027.
