Finland’s tax administration has released two guidance documents on the Minimum Tax Act, approved in late 2023 to implement the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523.

The first guidance was released on 10 March 2025. The purpose of the guide is to provide an overview of the minimum tax for large groups.  This guide provides an overview of the Minimum Tax Act, including its purpose, scope, and alignment with the Directive and OECD rules. It covers key topics such as identifying group units and jurisdictions, calculating effective tax rates and supplementary taxes, and applying minimum taxation rules like the Domestic Supplementary Tax (QDMTT), Income Inclusion Rule (IRR), and Under-Taxed Profits Rule (UTPR). It also addresses special provisions related to corporate restructuring, holding structures, single taxation, profit distribution tax regimes, and safe harbours.

The second guidance was issued on 12 March 2025. It offers detailed guidance based on OECD administrative guidelines published by June 2024. This guide explains how to calculate adjusted relevant taxes under Chapter 4 of the Minimum Tax Act, including profit distribution taxation. It also covers transitional provisions for relevant taxes and corporate mergers.

This guide explains the covered taxes that need to be considered, including adjusted taxes for the financial year, such as those based on taxable income and deferred taxes, along with adjustments to current and deferred taxes. This also involves defining loss selection, allocating applicable taxes, and determining a qualifying tax regime based on profit distribution taxation. Additionally, it addresses the adjustment of tax expenses from previous financial years, deferred tax assets and liabilities in M&As, and transitional provisions related to deferred taxes.