Finland's parliament has passed two amendments to its minimum tax law for large corporations, bringing its rules in line with the latest OECD and G20 global standards — and racing against a 31 March 2026 deadline to avoid exposing Finnish multinationals to double taxation.
Finland’s parliament adopted the law proposals HE 196/2025 and HE 6/2026 on 11 March 2026, amending the Law on Minimum Tax by Large Groups (Pillar Two rules) to align with new international guidance and strengthen enforcement mechanisms.
The proposal serves three main purposes: incorporating OECD and G20 implementation guidance from 2024 and 2025, allowing the Tax Administration to issue advance rulings in specific cases, and introducing a general anti-avoidance provision for minimum tax matters.
Finland’s minimum tax legislation implements EU Council Directive 2022/2523, which establishes a global minimum tax rate for multinational and large domestic groups. The directive follows the OECD/G20 Inclusive Framework’s Pillar Two initiative. To maintain Finland’s “qualifying rules” status internationally, the amendments will codify new tax rules and clarifications on complex interpretative issues from recent OECD guidance, while other interpretative points will be addressed through administrative practice.
The amendments will affect Chapters 1–6 and 8–10, alongside technical corrections. Importantly, the law’s core principles remain unchanged—the scope of affected taxpayers, tax rate, and fundamental taxation rules stay intact.
The Act should take effect by 31 March 2026 at the latest. Most provisions will apply retroactively to financial periods starting 1 January 2024. However, the new anti-tax avoidance provision in Chapter 8 will only apply to financial periods beginning 1 January 2027 and onwards.
The amendments also build upon the government’s existing proposal (HE 196/2025 vp). It introduces several presumption rules to align with international standards, including provisions for parallel systems, ultimate parent entities, and tax incentives based on net assets. Additionally, the transitional presumption rule for country-by-country reporting will be extended by 12 months.
These proposals stem from Article 32 of the Minimum Tax Directive and the parallel model package released by the OECD and G20 Inclusive Framework in January 2026. While the presumption provisions are expected to significantly influence how the global minimum tax system operates, Finland anticipates primarily indirect effects. The supplementary tax collected domestically is not projected to decrease substantially.
The legislation aims for rapid implementation, with an entry into force deadline no later than 31 March 2026. Once enacted, the provisions will apply to financial periods starting on or after 1 January 2026.
The law will be published in the Official Gazette after the President’s ratification.
Earlier, on 23 January 2026, Finland’s Ministry of Finance launched a public consultation on proposed amendments to the Minimum Tax Act to implement the OECD/G20 Pillar 2 global minimum tax rules, which ended on 4 February 2026. The proposals would modify the Supplementary Tax Act for Large Groups and update the government proposal HE 196/2025, which was under review by the Parliament.
