Finland: MFN clause applies in tax treaty with Lithuania
On 2 September 2019, Finnish tax authority published a statement no.67/2019 regarding the application of the most-favored nation (MFN) clause in article 12(7) (Royalties) of Finland’s tax treaty with Lithuania. Under the MFN clause, effective
See MoreFinland: Ministry of Finance announces the budget proposal for 2020
On 16 August 2019, the Finnish Ministry of Finance announced the proposal for the 2020 budget package. The proposal includes following tax measures: A gradual increase tobacco tax by EUR 200 million over the period 2020 to 2023An increase in
See MoreFinland: Tax administration publishes guidelines on interest limitation rules
On 7 March 2019, the Finnish tax administration published new guidelines on the rules on interest deduction restrictions, which were amended to comply with EU Anti-Tax Avoidance Directive (ATAD), and contained a general 25% EBITDA interest deduction
See MoreFinland gazettes the law implementing the controlled foreign company (CFC) rules
On 31 December 2018, a law was published on the implementation of CFC rules in line with EU directive (EU) 2016/1164 (2016) as adopted by the parliament which is incorporated into Finnish legislation as a Law No. 1364/2018. The law introduced
See MoreFinland: Ministry of Finance publishes law on interest restriction rules
On 27 December 2018, Finland published Law 1237/2018 in the Official Gazette concerning new interest deduction restriction rules that are compliant with the EU Anti-Tax Avoidance Directive (ATAD). The law extends the limitation to interest paid on
See MoreFinland: Ministry of Finance submits a bill on changes to CFC rules to Parliament
On 1 November 2018, the Ministry of Finance submitted a bill to Parliament proposing changes to the CFC rules. Under the proposed rules, the control threshold setting the CFC status would be reduced from 50% to 25%, and the direct or indirect
See MoreFinland publishes a bill on the new interest deduction limitation rules
On 28 September 2018, the government issued a bill on its final proposal to amend national rules on the deductibility of interest expenses under the EU Anti-Tax Avoidance Directive (2016/1164 / EU). According to proposal, the deductibility of net
See MoreFinland: Ministry of Finance issues a draft bill proposing amendments to the CFC rules.
On 6 August 2018, the Finnish MoF published a draft consultation on a draft law that proposed changes to the Finnish CFC rules. The draft law aims to implement the CFC provisions contained in the EU ATAD. The bill would introduce changes to the CFC
See MoreFinland: Ministry of Finance officially submits its budget proposal for the year 2019
On 9 August 2018, the Ministry of Finance officially submitted its budget proposal for next year 2019. The budget introduced changes to the CFC definition and applicable exemptions, including reducing the control threshold for a company that
See MoreHong Kong and Finland enter into comprehensive avoidance of double taxation agreement
On 24 May 2018, Hong Kong and Finland signed a comprehensive avoidance of double taxation agreement (CDTA). The CDTA sets out the allocation of taxing rights between the two jurisdictions and will help investors better assess their potential tax
See MoreFinland: Tax administration issued guidelines on the allocation of profits to PE
On 30 April 2018, the tax administration published a guideline no.A72/200/2018 on profit distribution for a permanent establishment (PE). The guidelines clarify that, upon request, a foreign company has to specify how it has allocated profits to a
See MoreFinland: Parliament adopts a bill aligned with EU Directive on Exchange of Information
On 6 April 2018, Parliament adopted a bill amending the relevant provisions of the Taxation Act in order to clarify the wording of the provisions of Council Directive (EU) 2016/881 of 25 May 2016 on administrative cooperation in the taxation of
See MoreOECD: Third round of peer reviews on dispute resolution mechanisms
On 12 March 2018 the OECD released the third round of peer reviews relating to improving tax dispute resolution mechanisms to make them more timely, relevant and effective. Action 14 of the action plan on base erosion and profit shifting (BEPS) was
See MoreFinland: Tax administration publishes new guidance on TP documentation
On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007. The documentation requirement is divided into a master file and a local file. The
See MoreFinland:Ministry of Finance publishes draft bill on deduction of interest payment
On January 19, 2018, the Finnish Ministry of Finance published a draft government bill containing proposed changes on the deduction of interest paid to related parties. The Ministry of Finance has requested comments from interested parties by the
See MoreFinland raises tax on alcoholic beverages
Finnish taxes on alcoholic beverages increased at the beginning of 2018 after parliamentary vote last month. The Ministry of Finance confirmed that taxes on alcoholic beverages would increase by an average of 10 percent, increasing retail prices by
See MoreFinland: Government proposes to align CbC reporting with EU Directive
On 19 December 2017, Bill No. 191/2017 was submitted to the parliament as a proposal to amend section 14 d of the Act on Taxation Procedure which is in line with Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU. The
See MoreSpain: Cabinet approves the DTA with Finland
On 6 October 2017, the Cabinet of Spain approved the Double Taxation Agreement (DTA) with Finland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and effective, the new treaty
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