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Finland: Amendments to residency rules for certain foreign funds

Effective January 1, 2027

august 4, 2026

The president in June 2026 ratified amendments to the permanent tax residence rules for certain foreign undertakings for collective investment in transferable securities (UCITS) and alternative investment fund (AIF) funds—effective January 1, 2027.

The amendments provide that qualifying foreign funds are not considered to have an effective place of management (and thus tax resident) in Finland solely on the basis of activities carried on in Finland by its management company, provided certain conditions are met (e.g., regarding the independence and arm's length remuneration of the management company).


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

Markku Lepistö | markku.lepisto@kpmg.fi

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