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Finland: Guidance on identifying groups and allocating income under Pillar Two minimum tax rules

Explains how to determine domestic and multinational groups, apply the €750 million revenue threshold, and identify in-scope and excluded group entities

may 22, 2026

The Finnish tax administration issued guidance (Finnish) (April 9, 2026) on identifying groups and allocating income under the minimum tax rules for large groups, effective from April 9, 2026.

The guidance explains how to determine domestic and multinational groups, apply the €750 million revenue threshold, and identify in-scope and excluded group entities under the minimum tax act.

It also provides principles for determining the location of group entities and allocating annual consolidated revenues to group units, aligned with OECD Pillar Two administrative guidance.


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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