Finland: Amendments to Pillar Two rules enacted
The new law incorporates elements from the Inclusive Framework’s side-by-side package.
The Finnish Official Gazette on March 24, 2026, published Law No. 187/2026 (Finnish), which introduces amendments to the Minimum Tax Act, further aligning Finland’s Pillar Two rules with the latest OECD administrative guidance.
The new law incorporates elements from the Inclusive Framework’s side-by-side (SbS) package that was released in January 2026, including the:
- SbS safe harbor
- Ultimate parent entity (UPE) safe harbor
- Substance-based tax incentive safe harbor
- Extension of the transitional country-by-country reporting safe harbor (TCSH)
Notably, the simplified effective tax rate safe harbor has not been included yet but will be later this year.
Other amendments to the Finnish Pillar Two rules include:
- Implementation of elements from the OECD June 2024 Administrative Guidance and January 2025 Administrative Guidance.
- The scope of domestic advance rulings has been expanded, allowing taxpayers to obtain binding clarification on issues such as Finnish top-up tax calculations, entity status, or the application of certain safe harbors.
- Introduction of a general anti-avoidance rule (GAAR) aimed specifically at countering arrangements designed to circumvent the minimum tax rules or manipulate safe harbor eligibility.
The amendment generally applies to fiscal years beginning on or after January 1, 2024, except for the new anti-avoidance rule (fiscal years beginning on or after January 1, 2027) and the new safe harbor provisions (fiscal years beginning on or after January 1, 2026).
Read an April 2026 report prepared by KPMG’s EU Tax Centre