Finland’s Minimum Tax for Large Multinational Groups: What You Need to Know in 2026

Finland has taken significant steps to implement the OECD/G20 Inclusive Framework’s Pillar Two global minimum tax, joining more than 140 jurisdictions committed to ensuring that large multinational enterprises (MNEs) pay a minimum effective tax rate (ETR) of 15% in every country where they operate. The OECD’s Pillar Two rules—also known as the Global Anti‑Base Erosion (GloBE) rules—apply to multinational groups with annual consolidated revenues of at least €750 million. These rules require companies to calculate ETRs on a jurisdictional basis and pay top‑up taxes in countries where their ETR falls below 15%.

Finland’s Minimum Tax Act took effect for accounting periods beginning on or after December 31, 2023. The law was further amended at the end of 2024 and in 2025 to reflect new OECD Administrative Guidance. Any multinational group operating in Finland with consolidated global revenues of at least €750 million in two of the past four fiscal years falls within scope. Finland follows the OECD’s jurisdictional ETR calculation. If the effective tax rate falls below 15%, a domestic top‑up tax (QDMTT) may be applied.

The Pillar Two framework introduces significantly broader and more technically demanding reporting obligations than before. In Finland, the reporting structure is based on the OECD’s GloBE Information Return (GIR) standard, which harmonizes reporting across all implementing jurisdictions and ensures that tax authorities can effectively assess multinational groups’ effective tax rates and potential top-up taxes.

All multinational groups within the scope of the minimum tax must file a GloBE Information Return (GIR) within 15 months from the end of the financial year. However, for the first reporting year, the deadline is extended to 18 months. The first GIRs need to be filed by 30 June 2026. The GIR may be submitted centrally by the ultimate parent entity or by a designated filing entity. Once filed in Finland, the GIR is automatically exchanged with tax authorities in other jurisdictions where group entities operate. If filing is done from a jurisdiction without a competent authority agreement with Finland, Finnish entities must file their own GIR locally.

When a multinational group submits its GloBE Information Return (GIR) in a jurisdiction outside Finland, any Finnish group entity — or another entity appointed by the group in Finland — must file a separate notification in Finland. This notification must identify the entity responsible for submitting the GIR abroad and specify the jurisdiction from which the report is filed.

Any Finnish group entity that becomes liable to pay a top-up tax for a given financial year under the minimum taxation rules must submit a separate top‑up tax return in Finland. The purpose of this filing is to provide the Finnish Tax Administration with all information necessary to determine the amount of top‑up tax and to carry out the assessment process. The first top-up tax return must be filed 30 June 2026.

Transitional CbCR safe harbour rule applicable to financial years commencing on or before 31 December 2026 and ending no later than 30 June 2028 applies when a jurisdiction meets one of the following conditions:

• Effective tax rate of at least 15% for FY2024, 16% for FY2025, and 17% for FY2026
• Revenue below EUR 10 million and profit below EUR 1 million
• Profits not exceeding the substance-based income exclusion.

These conditions rely on a qualified CbC report and qualified financial statements. The CbCR safe harbour is applied separately for each jurisdiction, based on the group’s own choice. If the CbCR safe harbour is applied for a jurisdiction, the GIR only requires the simplified set of data related to the safe harbour criteria—such as jurisdictional revenue, profit/loss before tax, simplified taxes, and information needed for the substance‑based income exclusion. In the recently issued government bill 6/2026, it has been proposed that the period of application of the transitional CbCR safe harbour rule is extended by one year. The effective minimum tax rate for financial year 2027 would be 17%.

The top-up tax is lowered to zero for the first five fiscal years for large domestic groups beginning from the first fiscal year in scope. This covers fiscal years 2024–2028. Reporting obligations remain in force: GIR must be filed, but domestic groups do not file notifications and cannot have a payable top-up tax during the transition.

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