The consultation ends on 19 November 2025.
Finland’s Ministry of Finance has launched a public consultation on proposed changes to the Minimum Tax Act on 11 November 2025 to maintain compliance with the EU Minimum Tax Directive (2022/2523).
The legislative change would ensure that corporate groups with an annual turnover exceeding EUR 750 million pay at least a 15% tax on their worldwide income. The proposal includes amendments to the current act based on OECD guidance published in 2024 and 2025. The act would also be supplemented with provisions on advance rulings and tax avoidance.
The changes would clarify the act, and existing principles would remain unchanged. There would be no changes to the scope of application, calculation basis, or the minimum tax rate.
The purpose of the proposal is to amend the Act on the Minimum Tax for Large Groups (1308/2023) to take into account the implementation guidance on minimum taxation produced in 2024 and 2025 within the framework of the OECD and G20 Inclusive Framework. In addition, the proposal aims to enable the Tax Administration to issue advance rulings in certain situations within the scope of the law and to introduce a general tax avoidance provision into national regulation.
The Act on the Minimum Tax for Large Groups is based on Council Directive (EU) 2022/2523, which establishes a global minimum tax rate for multinational groups and large domestic groups within the Union.
The Directive builds on the work on minimum taxation in the Inclusive Framework (Pillar 2), and the implementation of its objectives requires that domestic legislation aligns with the interpretations produced by the Inclusive Framework. Compliance with these interpretations in domestic tax practice is also necessary for Finland’s minimum taxation rules to be recognised internationally as qualifying rules.
The Ministry of Finance requests comments on the proposal by 19 November 2025.
The amendments will take effect in the first half of 2026. They would apply to accounting periods beginning on or after 1 January 2024, except for the new anti-avoidance rule.
