Finland’s Minimum Tax Act implements the EU and OECD Pillar 2 framework by introducing a 15% global minimum effective tax rate for large multinational and domestic groups. The regime focuses on jurisdictional effective tax rate calculations and the imposition of a supplementary tax in low-tax jurisdictions, ensuring consistent alignment with evolving OECD administrative guidance.
Finland’s tax administration has published new guidance on 20 January 2026 on the minimum taxation of large groups under the Pillar 2 global minimum tax framework.
The guidance provides detailed explanations on the calculation of the effective tax rate (ETR) and the supplementary (top-up) tax under Finland’s Minimum Tax Act (1308/2023), which implements the EU Pillar 2 rules in line with Council Directive (EU) 2022/2523.
The Finnish minimum tax regime transposes Council Directive (EU) 2022/2523, which establishes a 15% global minimum tax rate for large groups operating within the EU. In applying the Act, the Finnish Tax Administration relies on national legislative materials and the OECD’s Pillar 2 GloBE Commentary (2025) and Administrative Guidance (July 2023).
The calculation of the effective tax rate is central to the system. Where a group’s jurisdictional ETR falls below 15%, the jurisdiction is classified as a low-tax jurisdiction, and the relevant entities are treated as low-taxed constituent entities. In such cases, a supplementary tax is calculated to ensure the minimum level of taxation and allocated among group entities in accordance with the Act.
This guidance provides a high-level framework for interpreting Finland’s minimum tax rules and supports consistent implementation of the EU and OECD global minimum tax standards.
Structure of the guide
The guide is structured as follows:
- Chapter 1 (Introduction) sets out the background, legal framework, and key definitions relevant to the minimum tax, effective tax rate, and supplementary tax.
- Chapter 2 provides a detailed explanation of how the effective tax rate is calculated at the jurisdictional level.
- Chapter 3 addresses the calculation and allocation of the supplementary tax arising in low-tax jurisdictions.
Together, these chapters provide a practical and interpretative framework for understanding Finland’s implementation of the global minimum tax and its interaction with OECD Pillar 2 rules.
Earlier, Finland’s tax administration released two guidance documents on the Minimum Tax Act, approved in late 2023 to implement the Pillar 2 global minimum tax.
