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Finland: Guidance on global minimum tax, qualified domestic minimum top-up tax; legislation implementing DAC9

Calculating effective tax rate and QDMTT; legislation to implement DAC9

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February 18, 2026

The tax administration on January 20, 2026, published guidance (VH/3994/00.01.00/2025) focusing on calculating the effective tax rate (ETR) and the qualified domestic minimum top-up tax (QDMTT) under the Minimum Tax Act, for purposes of the global minimum taxation of multinational enterprise (MNE) and large domestic groups under OECD Pillar Two. It includes examples and details on how substance-based deductions may reduce net income based on costs or assets.

In addition, the government in late December 2025 published legislation implementing Directive (EU) 2025/872 (DAC9), which is effective on January 1, 2026. The law implements DAC9 reporting and exchange of information rules into Finnish law, streamlining filing obligations for multinational enterprise groups and large domestic groups.


For more information, contact a KPMG tax professional in Finland:

Johanna Männistö | johanna.mannisto@kpmg.fi

Erkki Tiitta | erkki.tiitta@kpmg.fi

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