Finland: Consultation on amendments to interest deduction limitation rules for critical entities financing long-term infrastructure projects

Consultation closes May 30, 2025.

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April 30, 2025

The Ministry of Finance on April 9, 2025, launched a public consultation on a draft proposal amending the interest deduction limitation rules that would allow critical entities (as defined under the Critical Entities Resilience (CER) Directive of December 14, 2022 (2022/2557)) to fully deduct borrowing costs resulting from loans related to financing long-term infrastructure projects deemed critical for security of supply.

The proposal builds on the exemption of long-term public infrastructure projects under the Anti-Tax Avoidance Directive (ATAD). Under the proposal, and in accordance with the CER directive, entities must be identified as critical operators by July 17, 2026.

The consultation closes May 30, 2025.

Read an April 2025 report prepared by the KPMG’s EU Tax Centre

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