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Finland: New guidance issued on application of Pillar Two safe harbor provisions

Clarifications and examples on the application of Pillar Two safe harbor provisions

April 22, 2026

The Finnish tax authorities on April 13, 2026, issued new guidance providing clarifications and examples on the application of Pillar Two safe harbor provisions in Finland.

The guidance provides clarifications on the application of:

  • Transitional country-by-country (CbC) reporting safe harbor
  • Transitional under-taxed profits rule (UTPR) safe harbor
  • Exclusion for the initial phase of international activity
  • Simplified calculations for non-material constituent entities
  • Side-by-side safe harbor
  • Ultimate parent entity (UPE) safe harbor
  • Substance-based tax incentive (SBTI) safe harbor

Read an April 2026 report prepared by KPMG’s EU Tax Centre

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