Finland’s Parliament has approved the ratification of the fourth protocol to its 1991 tax treaty with Switzerland, introducing OECD BEPS-aligned anti-abuse and arbitration provisions and expanding Finland’s taxing rights over voluntary and supplementary pensions.
Finland’s Parliament has approved the Government Proposal HE 159/2026 vp to ratify the amending protocol to the 1991 tax treaty with Switzerland on 6 October 2026.
Signed on 28 May 2026, the protocol aligns with OECD BEPS minimum standards by denying treaty benefits in cases of abuse and introducing arbitration for mutual agreement procedures. It also allows Finland to tax voluntary and supplementary pensions regardless of the recipient’s citizenship or tax status, with existing treaty rules used to prevent double taxation.
It will enter into force 30 days after the exchange of ratification instruments and will apply from 1 January of the year following its entry into force.
Earlier, Finland’s government submitted a bill to Parliament seeking approval of the amending protocol to the Finland–Switzerland Income and Capital Tax Treaty (1991) on 10 September 2026.
