Finland

1. Overview    

1.1. Government and Tax System 
Finland is a parliamentary republic, and the capital is Helsinki. Finland has been a member of the European Union (EU) since 1995.
Finnish corporate income is taxed at a national flat rate of 20 percent. Corporations are taxed on their worldwide business income. Generally, capital gains and losses are taxed as part of ordinary business income. However, in special situations capital gains are exempted (and losses are nondeductible).
Personal income is also taxed on a national level, however a municipal tax and church tax (for taxpayers who are members of the Evangelical-Lutheran or Orthodox church) also apply.
Taxable income of individuals is divided into earned income and capital income. Capital income is the income generated through the possession of assets, such as capital gains and interests, and it is taxed on a progressive scale. Tax on capital income is carried out at the federal level, but municipalities may impose income tax on capital yields taken from the allocated tax revenue.
The main source of tax laws in Finland are various acts and regulations issued pursuant to regulation-making authority. The Central Board of Taxation and the Supreme Administrative Court publish decisions with precedent value. In addition, decisions of the European Court of Justice are binding on Finnish courts on questions of EU law. The tax authority publishes administrative guidance.
The Ministry of Finance and the tax authority administer tax in Finland.

1.2. Currency 
The currency of Finland is the euro.

1.3. Membership of International Organizations 
Finland is a member of the European Union (EU), World Trade Organization (WTO), Organization for Economic Cooperation and Development (OECD), International Labor Organization (ILO), International Monetary Fund (IMF), and World Customs Organization (WCO).

1.4. Official Websites 
The following official websites are relevant in Finland: 
###$$$ Tax Authority — https://www.vero.fi/henkiloasiakkaat/. 
###$$$ Finance Ministry — http://www.vm.fi/vm/en/01_main/index.jsp. 
###$$$ Business Finland — https://www.businessfinland.com. 
###$$$ Team Finland (Investment Promotion) — https://www.team-finland.fi/en. 

1.5. Automatic Exchange of Information 
For treaty information, including the number of agreements signed or in force, original treaty texts, translations, and consolidations, see the International Tax Treaties Collection.
Finland has ratified the Convention on Mutual Administrative Assistance in Tax Matters.
Finland is a signatory to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information, and has enacted legislation to implement the Common Reporting Standard (CRS).
Finland is a signatory to the Multilateral Competent Authority Agreement on Automatic Exchange regarding CRS Avoidance Arrangements and Opaque Offshore Structures ("the MDR-MCAA").
Finland has enacted legislation to implement the provisions of Directive 2014/107/EU (DAC2) (amending Directive 2011/16/EU (DAC)) on mandatory automatic exchange of tax information within the EU.
The EU, including Finland, has signed agreements to apply DAC (as amended by DAC2) with the following countries: 
###$$$ Andorra;
###$$$ Switzerland;
###$$$ Liechtenstein;
###$$$ San Marino; and
###$$$ Monaco.

Finland has enacted legislation to implement a FATCA Model 1 IGA with the United States.
Finland is a signatory to the Multilateral Competent Authority Agreement on the Automatic Exchange of Country-by-Country (CbC) Reports, facilitating implementation of the transfer pricing reporting standards developed under Action 13 of the OECD/G20 BEPS Project.
Finland is a signatory to the Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income derived through Digital Platforms ("the DPI-MCAA").
Finland is a member of the Inclusive Framework on BEPS, a group of countries that is developing standards on BEPS-related issues, and is reviewing and monitoring implementation of the OECD/G20 BEPS Project.

2. Corporate Tax Computation and Administration 

2.1. Residence, Taxable Status, Entity Characterization 

2.1.1. Residence 
In Finland, a company is deemed to be a resident of Finland if it is registered (i.e., established) in Finland.
Additionally, with effect from January 1, 2021, the tax liability of foreign corporate entities is determined by the place of effective management. The place of management is the place where the corporation's highest-level decisions concerning daily management are made.
Companies incorporated under Finnish law are subject to tax liability on worldwide income by filing a tax return. If a corporate entity is a resident taxpayer, then Finland has the right to tax its income from anywhere in the world.

2.1.2. Taxable Status 
Entities treated as partnerships are not treated as separate tax subjects in Finland. A partnership is only an accounting unit and its profits are taxed as income of the partners.

2.1.3. Legal Classification of Nonresident Entities 
Foreign entities are characterized according to the type of domestic entity they most resemble. A foreign entity that has a structure similar to a Finnish corporation or a limited company, which are subject to corporate tax, would be treated as corporations. Entities resembling Finnish partnerships, which are not subject to corporate tax, would be treated as transparent entities.
Companies or firms formed in accordance with the law of an EU Member State and having their registered office, central administration, or principal place of business within the EU qualify as EU nationals.

2.2. Corporate Tax Base 

2.2.1. Resident Corporations 
In Finland, the income tax base for resident companies is worldwide.
Income tax is generally imposed on all kinds of income.

2.2.2. Nonresident Corporations 
Finland may tax nonresident companies for profits from business conducted in Finland, dividends from Finnish companies, royalties or similar income from Finnish sources, and income from immovable property located in Finland, even though the activities would not constitute a permanent establishment (PE).
If a relevant tax treaty applies, the tax authority is not permitted to tax nonresident companies on income from their business conducted in Finland, unless the income is connected with the foreign company's PE situated in Finland.
For income tax purposes, "permanent establishment" is defined as a fixed place of business, through which the business of an enterprise is wholly or partly carried on. Treaty interpretation is generally based on the OECD guidelines.

2.2.3. Non-Corporate Business Entities 

2.2.3.1. Recognition 
Finland recognizes a number of other business entities, including general partnerships, limited partnerships, branches of a foreign company, private traders and entrepreneurs, and nonprofit associations.

2.2.3.2. Tax Status 
Branches of a foreign company are subject to income tax similarly to corporations. The profits of general partnerships, limited partnerships, private traders, and entrepreneurs are fully taxable as income to the owner-shareholder of the entity. The taxable income attributable to the operation of the trade or business is divided between a capital-income portion and an earned-income portion. Nonprofit organizations are tax exempt in general, but if they are engaged in business activity, the income from that activity is taxable.

2.2.4. Permanent Establishments 

2.2.4.1. Domestic Law Definition 
"Permanent establishment" is defined as a fixed place of business, through which the business of an enterprise is wholly or partly carried on. Finland imposes tax on the profit of a PE in the same way that a corporation is taxed.

2.2.4.2. Treaty Definition 
Finland generally uses the OECD definition as the definition of a PE in its treaty policy.

2.2.4.3. Creation via Performance of Services 
A services PE arises when building, construction, or installation work is being performed in Finland for longer than six, 12 or 18 months, depending on the relevant tax treaty.

2.2.4.4. Creation via Customer Downloads or Website Access 
The determination of whether a local customers' access of websites, downloading information, or any or other use of the internet creates a PE is evaluated on a case-by-case basis.

2.2.4.5. Creation via Cloud Services 
The determination of whether a local customers' access of websites, downloading information, or any or other use of the internet creates a PE is evaluated on a case-by-case basis.

2.3. Taxable Year 

2.3.1. Default Taxable Year 
In Finland, the tax year is the year during which the accounting period ends. The most common accounting period is January 1 to December 31. However, a company may choose to have a different accounting period of 12 months, e.g., February 1 to January 31.

2.3.2. Reference Year for Computation of Tax 
In a given taxable year, taxpayers are subject to tax on income earned in that year. For example, returns filed in 2025 with regards to the taxpayer's liability for the 2024 tax year, will report income from 2024 and calculate tax on that basis. For companies, a given taxable year is the year when the accounting period ended. Companies are liable to file a tax return within four months of the end of the accounting period.

2.4. Computing Taxable Income 

2.4.1. General 
Taxable income is determined by the company's profit and loss statement. Deductible operating expenses include the normal day-to-day expenses of running the business. Entertainment expenses are tax-deductible up to 50 percent of the total amount.

2.4.2. Exempt Income 
In general, a dividend distributed between companies is tax exempt.
In addition, certain capital gains arising from disposal of fixed asset shares are considered tax exempt, provided that preconditions laid down in legislation are met. Correspondingly, losses from the disposal of such shares are nondeductible. The tax exemption applies if the following conditions are satisfied: 
###$$$ the vendor company has, at the time of the disposal, owned at least 10 percent of the share capital of the target company for at least one year during a period that has ended not more than one year prior to the disposal of the shares;@@@%%%
###$$$ the sold shares are not shares in a real estate company or a housing company; and@@@%%%
###$$$ the disposed shares form part of the fixed assets of the vendor.

Tax exemption of fixed asset shares is only applicable to corporations with certain limitations, e.g., the tax exemption does not apply to housing companies or mutual real estate companies. Also excluded from the exemption are private equity firms. In addition, the target company must be either a Finnish company or a company to which the EC Parent—Subsidiary Directive (90/435/EEC) is applied or there must be a double tax treaty in place between Finland and the residence state of the target company.

2.4.3. Inventory Valuation and Inventory Flow 
Inventory may be valued at the lower of the cost of the goods or the market value. If the taxpayer is not able to prove which item is disposed of, in taxation, only the "first-in first-out" method (FIFO) may be used to record units moving into and out of inventory.

2.4.4. Depreciation or Capital Allowances 
Under Finnish tax laws, the maximum tax depreciation is 7 percent on warehouses, factories, logistic buildings, and retail stores and 4 percent on office buildings and comparables. For machinery, the maximum tax depreciation is 25 percent. No depreciation is allowed on land or shares. Intangible property must be depreciated using a straight-line method over its estimated useful life, with a maximum period of 10 years.
During tax years 2020 to 2025, a double depreciation is allowed for machinery acquired and taken into use during these years.1
According to Finnish case law, goodwill can be deducted as annual depreciation even if it has not been recorded in a company's accounts.

2.4.5. Reserves 
In general, certain reserves are permitted as deductions for tax purposes in limited situations. For example, reserves for bad debt are only allowed in the banking business.

2.4.6. Special Allowances 
An employer is entitled to an additional tax deduction for education promoting employees' professional know-how. The amount of the "education deduction" is determined in accordance with the number of employees participating in education and the average daily salary of all employees working for the employer.

2.4.7. Special Provisions or Limits Applicable to Foreign Companies 
There are no special provisions or limits applicable to foreign companies.

2.5. Intercompany Dividends 
In general, a dividend distributed between resident companies is tax exempt.

2.6. Special Tax Regimes 

2.6.1. Economic Zones 
There are no economic zones in Finland.

2.6.2. International Finance or Holding Companies 
There are no special tax regimes for international holding companies in Finland.

2.6.3. Research and Development Companies and Activities 
 Additional deduction for R&D subcontracting costs 
During tax years 2022 to 2027, a taxpayer engaged in a commercial or agricultural activity may (subject to conditions) make an additional deduction of subcontracting costs invoiced by a research organization within the definition of the law. The additional deduction is 150 percent of qualifying costs incurred in tax years 2022 to 2027. The additional deduction is capped at 500,000 euros in a tax year, with a minimum deduction of 5,000 euros.
The deduction is also available to taxpayers with limited tax liability in Finland and to permanent establishments that exercise research and development activities in Finland.
The subcontracting costs must be based on the cooperation between the taxpayer and development activities of the research organization. The basis of the additional deduction is the subcontracting invoice of the research organization.
 Additional deduction for R&D salary and service costs 
Law 1298/2022 introduces an additional combined tax incentive for taxpayers engaged in business or agriculture and carrying out R&D activities from a fixed location in Finland. The incentive consists of (i) a general additional deduction based on the R&D expenditure incurred, and (ii) a supplementary additional deduction based on the increase in R&D costs as compared to the previous year.
The general deduction is available from tax year 2023 and is 50 percent of the taxpayer's R&D related salary and external party service costs. The deduction is capped at 500,000 euros in a tax year, with a minimum deduction of 5,000 euros. The general deduction is not available for costs on which the additional deduction for R&D subcontracting costs (see above) has been claimed.
The supplementary deduction is available from tax year 2024 and is 45 percent of any increase in the above R&D costs compared to the previous year. The deduction is capped at 500,000 euros in a tax year and there is no minimum deduction.
This combined tax incentive is not available if the taxpayer has received other public support for the same expenses.

2.6.4. Other Special Regimes 
There are no other special regimes.

2.7. Double Taxation Protection 

2.7.1. Mechanics 
Tax treaties determine the extent to which and the method by which the tax authority must eliminate double taxation in a tax treaty situation. The tax authority must eliminate double taxation with the credit method or the exemption method. The applicable method depends on both the treaty and the item of income concerned. The credit method is the primary method in most of Finland's tax treaties.

2.7.2. Treaty or Statutory Priority 
If an income tax treaty provides a rate of tax higher than the statutory rate on that item of income, the more favorable rate is applied.
If a treaty lowers the rate of tax on an income item, the nonresident is permitted to establish a right to the lower rate before the income is paid.
For treaty information, including the number of agreements signed or in force, original treaty texts, translations, consolidations and any modifications made by the Multilateral Instrument, if applicable, see the International Tax Treaties Collection.

2.7.3. Source of Interpretation 
In general, Finland follows the OECD model treaty and commentary in its treaty policy and interpretation.

2.8. Returns and Filing Dates 

2.8.1. Filing Deadline 
Corporate tax returns are due within four months after the end of the financial year.

2.8.2. Filing Method 
As a general rule, corporations must file their tax returns electronically. Paper filing is allowed only if special, qualified reasons exist.

2.8.3. Extensions 
An extension is possible if weighty reasons exist. If an extension is granted, the last possible date to file the tax return is case-specific.

2.8.4. Penalties 
A late-filing penalty of 100 euros may be payable where a company files an income tax return after the filing deadline, but before the tax assessment has been completed.
Where a tax return is filed on time, a late-filing penalty of 100 euros may still be payable if, on the company's own initiative, additions or corrections are made after the filing deadline but before completion of the tax assessment. A late filing penalty is generally only imposed in such circumstances if the changes increase the amount of taxable income.
If an income tax return is filed after the end of the tax assessment, a company will have to pay a punitive tax increase calculated in accordance with a formula. The minimum amount of tax increase is 150 euros and there is no maximum limit. A punitive tax increase may also be imposed if the filed return is incomplete or inaccurate.

2.9. Payment Mechanics 

2.9.1. Internal Withholding on Resident Companies 
A payer of compensation does not have to withhold tax on payments made to a provider of services if the provider is entered in the prepayment register kept by the tax authorities. However, if the payment made to the taxpayer is nonwage compensation or royalties, and the taxpayer is not prepayment-registered, the payer is required to withhold tax.
Withholding on payments made to incorporated legal entities (including limited liability companies and cooperative societies) and tax consortia (including general and limited partnerships) should be made at the 13 percent rate.

2.9.2. Schedule for Tax Payments or Deposits 
Companies are required to make prepayments of tax on income received from business operations, agricultural operations or other production of income, such as rental or sales of assets. The tax authority will calculate the prepayment amount based on the company’s latest finalized tax assessment. The prepayments can be changed during the tax year. The due date for tax prepayment is the 23rd of each month. 
Prepayments are not collected if the amount of tax to be prepaid is less than 500 euros. The prepayment of taxes is carried out in either two or 12 installments depending on the total amount of tax payable. The prepayment of taxes is carried out at the third and ninth month of the financial year if the total amount of tax to be prepaid is between 500 euros and 2,000 euros. If the amount of tax to be prepaid exceeds 2,000 euros, the payment of the total amount of prepayment taxes is divided into 12 monthly amounts.
Prepayments are credited against the final tax due. Any tax remaining due is collected and any excess tax paid is refunded to the taxpayer after the tax assessment decision has been applied.

2.9.3. Electronic Payments 
There is no specific requirement to establish a local bank account as payments can be made from abroad. The real estate tax, prepayment tax and residual tax are payable through e-invoice, and electronic payment may become possible in the future for other taxes.

2.9.4. Interest and Penalties 
Late payment interest may become payable if the tax year has ended and a company's prepayments are not enough to cover its actual tax liability for the year. The interest will start to accrue on the first day of the second month following the end of the tax year. Companies can avoid having to pay late payment interest by making additional prepayments within a period of one month after the end of the tax year. The late payment interest is not deductible. 
In the case of tax fraud, the penalty is either a fine or a prison term of up to two years. In the case of aggravated tax fraud, the penalty is a prison term of four months to four years.

2.10. Statute of Limitations 
The general statute of limitations is three years from the January 1 following the end of a given financial period. Under certain conditions, the tax authorities may decide on a one-year extension to the general statute of limitations. Additionally, an assessment can be amended to the detriment of a company within a six-year period where:
•	a transfer pricing adjustment is made under Section 31 of the Act on Tax Procedure;
•	there is an arrangement between related parties relating to corporate or financing structures within the meaning of Section 31 of the Act on Tax Procedure; or
•	the amendment is based on information received through an international exchange of information other than an automatic exchange of information.

3. Corporate Tax Rates 

3.1. National Taxes 

3.1.1. Corporate Tax Rates 
Current rate: 20 percent
The tax rate for corporations is 20 percent.

3.1.2. Alternative Tax Regime 
Finland does not have an alternative tax regime.

3.1.3. Special Reduced Rates or Regimes 
There are no special reduced rates or regimes.

3.1.4. Special Additional Taxes or Levies 
There are no special regimes.

3.2. State, Cantonal, Provincial or Other Local Taxes 

3.2.1. Main Rates 
There are no state corporate taxes.

3.2.2. Reduced Rates 
There are no state corporate taxes.

3.2.3. Income Tax Base 
There are no state corporate taxes.

3.2.4. Income Tax Deductions 
There are no state corporate taxes.

3.2.5. Incentives 
There are no state corporate taxes.

3.2.6. Non-Income Taxes in States 
There are no state corporate taxes.

3.3. Taxes Imposed as a Penalty 
The tax authority may impose late payment fees and tax increases as a penalty if the taxpayer has not filed a tax return or paid taxes on time.

4. Corporate Tax Capital Gains, Losses, Group Treatment 

4.1. Taxation of Corporate Capital Gains 
Generally, capital gains and losses are taxed as part of ordinary business income.
In those cases where capital gains are taxable, losses are correspondingly deductible.
Losses may be deducted against regular business income. However, if the company is taxed in accordance with the Income Tax Act (and not the Business Income Tax Act, such as a mutual real estate company), losses on sales of shares may only be deducted against capital gains on disposal of shares during the five years following the year of the loss-making disposal.
Where an entity taxed in accordance with the Business Income Tax Act has losses on the sale of assets treated as "other assets" for tax purposes, the right to deduct losses is limited to five years following the year of the loss-making disposal.
A replacement reserve is possible under certain limited provisions for the gain received from the sale of a company's premises.

4.2. Definition of Corporate Capital Gains 
Capital gains are defined as sale proceeds and return on assets to the amount exceeding the undepreciated acquisition costs or invested amount.
For information about long-term gains and assets, please refer to [2.4.2]Section 2.4.2[end].

4.3. Computation 
Generally, capital gain is calculated by deducting the acquisition costs and sales costs from the sales price.
An exemption may apply to fixed asset shares as discussed in [2.4.2]Section 2.4.2[end].

4.4. Corporate Combinations and Divisions 

4.4.1. Mergers 
The Finnish special domestic law provisions on mergers are included in the Finnish Business Income Tax Act. The same provisions apply to domestic mergers and mergers involving a company from another EU Member State. The special provisions apply to a merger in which one or more corporate entities or business partnerships are dissolved without liquidation and all of the assets and liabilities of the dissolved company are transferred to another corporate entity or business partnership. A merger covered by the special provisions does not cause any direct tax consequences to the companies or their shareholders in Finland. The transferring company is not deemed to dissolve for tax purposes. Cash may be used as consideration, but it must not exceed 10 percent of the nominal value of the new shares issued by the recipient company; the transaction is deemed to be a taxable event for shareholders to the extent that cash compensation has been used.

4.4.2. Transfers of Corporate Property 
The Finnish special domestic law provisions on a tax-neutral transfer of assets are included in the Finnish Business Income Tax Act. The same provisions apply to domestic arrangements and arrangements involving a company from another EU Member State. A corporation may transfer all its assets or the assets of one or more branches of its business activity and the corresponding liabilities to a corporate entity (either newly created or, with effect from January 1, 2024, an existing company), which continues the activity. The transferring company receives new or already existing shares issued by the recipient company as consideration. A transfer of assets does not realize any taxable income, provided that remaining tax values are used as the transfer price in taxation. 

4.4.3. Share Transfers 
The Finnish special domestic law provisions on a tax-neutral exchange of shares are included in the Finnish Business Income Tax Act. The same provisions apply to domestic arrangements and to arrangements involving a company from another EU Member State. In an exchange of shares, a company limited by shares acquires a sufficient number of shares from another company limited by shares to give it the majority of the voting rights. The acquiring company issues new or already existing shares in exchange for the acquired shares. If money is used as consideration, the proportion of payment in money must not exceed 10 percent of the nominal value of the shares used as consideration. An exchange of shares is a transfer which, excluding the possible cash payment, does not realize taxable income or deductible costs. Because of the factual change in the ownership, the possible losses that were not deducted earlier may be lost.

4.4.4. Divisions or Separations 
The Finnish special domestic law provisions on divisions are included in the Finnish Business Income Tax Act. The same provisions apply to domestic divisions and divisions involving a company from another EU Member State. Under limited circumstances, a company can undergo a demerger without recognizing tax on any gain, and without shareholders being taxed on receipt of either company's shares. The Business Income Tax Act provides for two kinds of tax-neutral demergers, i.e., the complete demerger and the partial demerger. These are very tightly controlled transactions, with a number of conditions that must be met before the tax-free treatment is granted.

4.5. Position of Losses From Business Operations 

4.5.1. Definition 
An operating loss includes a capital loss. Foreign losses can be offset against domestic income if the foreign losses relate to a foreign PE in Finland.

4.5.2. Treatment 
Carrybacks — Operating losses cannot be carried back to prior years.
Carry forwards — Losses of a Finnish company may be carried forward and set off in the subsequent 10 tax years.

4.5.3. Losses After Change in Ownership 
As a rule, any tax loss carry-forwards from a given tax year are forfeited if more than 50 percent of the shares of the company change owner after that tax year. The same applies if more than 50 percent of the shares change owner in an entity holding at least 20 percent of the shares in the loss-making company.
Under certain conditions, a regional tax office may, upon application by a taxpayer, grant permission to deduct losses despite ownership changes. However, if a company has been granted this permission, the losses of the merging company are not sustained in the event of a merger.

4.6. Group Treatment 

4.6.1. General Rule 
Finland does not have group taxation. However, there are rules for a group contribution system available between Finnish group companies and PEs, under the following conditions: 
###$$$ the resident company (parent company) has owned, either directly or indirectly, during the entire tax year at least 90 percent of the shares of another resident company (subsidiary);
###$$$ both companies are engaged in business and are not financial, insurance or pension institutions;
###$$$ the accounting year of the paying and receiving companies ends on the same date, unless the Accounting Committee has granted an exception;
###$$$ the contribution is recorded in the annual accounts of both companies and affects their annual net income; and
###$$$ the contribution is not a mere capital investment.

Group contribution, subject to the conditions stated above, is taxable income for the receiving entity and tax deductible for the paying entity. A group contribution may not exceed the net taxable income of the paying company, and cannot be part of losses to be carried forward for tax purposes by that company.
If the above conditions are met, group contributions may generally be given and received also between Finnish subsidiaries that are held by the same foreign parent entity. 
In cross-border situations, Law 1198/2020 concerning group deduction applies with effect from January 1, 2021. Pursuant to the group deduction, the final losses of a subsidiary located in another EU/EEA member state can be deducted in the taxation of the Finnish parent company. The group deduction is applied to the limited liability companies and partnerships that can be considered as a receiver or issuer of group contribution. Financial, insurance, and pension institutions are excluded from the scope of the legislation.
For the application of the group deduction, the parent company must have at least 90 percent direct ownership in the subsidiary's share capital or units. The parent company must demonstrate the amount of losses of the subsidiary and their final nature within the meaning of EU law. The group deduction may be deducted up to an amount corresponding to the parent company's tax year taxable profit or loss. The deduction is made in the tax year in which the foreign subsidiary is dissolved.

4.6.2. Definition of Group 
Finland does not have group taxation. For the group contribution system, see [4.6.1]Section 4.6.1[end].

4.6.3. Special Aspects 
Finland does not have group taxation. For the group contribution system, see [4.6.1]Section 4.6.1[end].

5. Corporate Withholding Taxes on Nonresident Corporations 

5.1. Dividends 
The tax treatment of cross-border dividends depends on the domestic tax law of the countries concerned, the tax treaties completed between the countries, and the EU Parent-Subsidiary Directive.
 General and treaty tax rate 
As regards companies, the withholding tax rate is 20 percent. In tax treaty situations, the rate may be lower or the dividend may be tax exempt.
 Exemption 
Tax treaty provisions or the EC Parent Subsidiary Directive may prevent taxation in Finland.
Consistent with the Parent—Subsidiary Directive, if the foreign dividend recipient has a holding of at least 10 percent in the capital of the Finnish dividend distributing company, the dividend is tax exempt in Finland. However, to implement recent amendments to the Directive, Finnish tax law now provides that a dividend distribution is regarded as taxable income if it is tax deductible for the distributing entity, or if the distribution is an artificial arrangement (or a series of arrangements) with a principal purpose of achieving a tax benefit which is not in line with the purpose of the exempting provision.
In addition, under certain conditions, no tax will be withheld from payments of dividend if a similar transaction within Finland would be exempt from tax and the payment is made to an EEA-resident company (concerns also Liechtenstein) that would not receive full credit for the Finnish tax in its country of residence. Under Finnish court practice, the dividend tax exemption has been extended, under certain circumstances, to such companies outside the EEA that are comparable to Finnish companies limited by shares.
The conditions include the following: 
###$$$ the EEA resident company's legal form is similar to a Finnish corporate entity;
###$$$ the recipient company's country of residence has a mutual assistance/exchange of information agreement with Finland; and
###$$$ the recipient provides a report clarifying that in accordance with the treaties on avoiding double taxation applicable in the home state of the receiver of dividend, the withholding cannot be reimbursed in full.

Finland withholds a 15 percent tax on dividends, paid on shares considered to be investment assets of the dividend recipient, to certain corporate or other recipients that are EEA resident, or otherwise not entitled to the EU Parent—Subsidiary Directive exemption, and are resident in a state which exchanges tax information with Finland under the EU Assistance Treaty or an equivalent treaty. With effect from January 1, 2021, changes have been made to the tax treatment of dividends paid to nominee-registered shares. Unidentified dividend beneficiaries are subject to 35 percent tax at source when there is no knowledge of the applicable country of tax residence. If the beneficial owner has been identified, but it is unclear at what rate the tax at source should be withheld (e.g., the dividend beneficiary is identified as an investment fund, but it is unclear whether the fund is entitled to treaty benefits), the withholding tax rate is 30 percent. Dividends paid to nominee-registered shares held by a Finnish tax resident are subject to a 50 percent withholding tax if dividend beneficiary information is not given.
 Banks and insurance companies 
Finland withholds a 15 percent tax at source on Finnish-source dividends in the event the shares in the Finnish company belong to the investment assets of the recipient company and the recipient company is not a legal entity defined in the Parent—Subsidiary Directive, which holds at least 10 percent of the share capital in the Finnish company.
It should be noted that only banks, pension institutions and insurance companies may have investment assets as referred to above.
 Pension funds 
Pension funds receiving dividends on shares in Finnish companies they hold as a part of their investment assets are entitled to deduct from the gross amount of dividends the provision for pension liabilities in the same way as Finnish pension funds. The maximum deductible amount is proportionate to the share the Finnish dividends represent of the funds' turnover. The foreign fund is eligible for the deduction if the fund is: 
###$$$ comparable to a Finnish pension fund and resident within the EEA; or
###$$$ resident in a non-EEA state and (i) the recipient owns directly less than 10 percent of the share capital of the company paying the dividends; (ii) the recipient fund is resident in a country which has an agreement providing for exchange of information with Finland; and (iii) Finland is able to obtain from the nonresident fund's state of residence the necessary information for the purposes of the tax assessment.

It is further required that the nonresident fund provides the Finnish tax administration the information relevant for the calculation of the deduction claimed, together with an explanation of the basis the deduction is claimed on.
There is a 15 percent withholding tax on (net) dividends paid to a pension fund that is either: 
###$$$ an EEA-resident comparable to a Finnish pension fund, and not otherwise an entity qualifying under the EU Parent—Subsidiary Directive holding directly at least 10 percent of the capital of the company distributing the dividends; or
###$$$ a non-EEA-resident pension fund comparable to a Finnish pension fund, holding directly less than 10 percent of the capital of the Finnish company paying the dividends, and which is resident in a country that has concluded an agreement on exchange of information with Finland, provided that sufficient information for purposes of the tax assessment is de facto obtained from the recipient's state of residence.

The normal 20 percent withholding tax applies to dividends paid to all other corporate form pension funds. A lower rate may be provided for in the relevant tax treaty.

5.2. Interest 
In practice, Finland very rarely taxes Finnish-source interest of a foreign company. The return paid on debt is usually treated as interest for Finnish tax purposes. Interest is tax exempt for a nonresident company if it is paid on foreign trade credit accounts, assets deposited in a financial institution, a bond, a debenture or other mass instruments of debt or any loan from abroad to Finland, which is not comparable to an equity investment. A loan is raised abroad if the debtor is a company subject to limited tax liability in Finland.

5.3. Royalties 
In principle, royalties paid to a nonresident company by a Finnish payer are subject to Finnish withholding tax of 20 percent for companies, unless tax treaty provisions or the EC Interest and Royalties Directive prevent/reduce the taxation in Finland. Royalties meeting the requirements under the domestic law implementation of that directive (broadly, royalties paid by a Finnish company to an "associated company" resident in another EU Member State) are exempt.

5.4. Services 
Generally, services income derived by a nonresident corporation is subject to Finnish taxation (by way of assessment) only if such a corporation has a PE in Finland.
However, when paying fees, nonwage compensation or other remuneration for work performed in Finland, the Finnish service recipient is required to withhold 13 percent (from payments to foreign limited liability companies or other corporations) or 35 percent (from payments to foreign self-employed entrepreneurs) as tax at source.
However, no withholding is necessary if the foreign entity/entrepreneur: 
###$$$ is prepayment registered in Finland; or
###$$$ shows the service recipient a tax card with a zero withholding rate; or
###$$$ shows the service recipient other documentation that prevents tax withholding.

If payment (leasing fees, compensation, remuneration, etc.) is made for work in a building site, or a construction, installation or assembly project, other civil engineering project, shipbuilding, transport services, cleaning services, nurse services, and childcare services, the service recipient always has the obligation to withhold tax, unless the entity/entrepreneur: 
###$$$ is prepayment registered; or
###$$$ shows a tax card with zero rate.

5.5. Other Withholding Taxes 
There are no other withholding taxes.

5.6. Special Tax Havens Rates 
There are no special tax havens rates.

6. Personal Taxes 

6.1. Domicile and Residency Requirements 
An individual is deemed to be resident in Finland and subject to unlimited tax liability if he or she has his or her main abode in Finland or if he or she stays in Finland for a continuous period of more than six months during one calendar year, or if the continuous six-month period in issue straddles two calendar years.

6.2. Income Tax Base 

6.2.1. Tax Base for Residents 
Each taxpayer may be subject to either unlimited or limited tax liability in Finland. The tax liability status is determined in accordance with Finland's domestic tax law. A Finnish resident individual or a Finnish estate of a deceased person is subject to unlimited tax liability in Finland whereas a nonresident is subject to only limited tax liability in Finland. Tax treaties or EU tax law do not as such affect a taxpayer's status as a person subject to unlimited or limited tax liability in Finland. However, tax treaties may contain a "tie-breaker rule" determining the state of residence in cases where a person is resident in several states based on the domestic tax laws.
A Finnish resident taxpayer subject to unlimited tax liability is liable to tax on his or her worldwide income. A taxpayer who is a Finnish resident only for a part of a tax year is treated as a person subject to unlimited tax liability only for that part of the tax year. Where the taxpayer is treated as a person subject to limited tax liability immediately after moving, he or she is liable to tax only for the part of the income which has been accrued from Finland from the date of moving to Finland.

6.2.2. Tax Base for Nonresidents 
Nonresidents are subject to limited tax liability. Persons subject to limited tax liability are subject to taxes in Finland for Finnish-sourced income. An exemplary list of the items regarded to be Finnish source is included in the Income Tax Act. However, certain Finnish-source items may be tax exempt according to a special provision.

6.2.3. Personal Income Subject to Income Tax 
Individuals are generally subject to tax on all income, which is divided into earned income and capital income. Capital income is the income generated through the possession of wealth. All other income is earned income. The individual separates the part regarded as capital income, and then treats the rest of the income as earned income. Certain capital gains are exempt from tax.
Fringe benefits are always considered as taxable income according to the fair market value of the benefit for the employee.
Service income that relates to work performed in Finland may be taxable income.
 Taxation of income earned abroad (the "six-month rule") 
Salary income for (generally full-time) employment abroad lasting for at least six months is tax exempt under Section 77 of the Income Tax Act if the following conditions are fulfilled: 
###$$$ the employee does not reside in Finland for more than six days per month on average in the period during which the work is performed abroad;
###$$$ the employment is not on board a Finnish vessel or aircraft;
###$$$ the employer is not the Finnish state, a Finnish municipality or any other Finnish public body; and
###$$$ the country in which the work is performed is not prevented from taxing the income in question by a provision of a tax treaty (if no treaty is in place between Finland and the country in which the work is performed, this condition does not apply).

If these conditions are fulfilled, the salary income from the employment abroad is entirely exempt in Finland. In practice, the income exempt from tax is not taken into account in determining the applicable tax rate for the salary income that is taxable income in Finland (i.e., the exemption is not "exemption with progression").
The six-month rule applies both to situations in which the employee has a local employer abroad (i.e., has a local employment contract) and those in which the employee is assigned to work abroad by his or her Finnish employer. However, if the employee is covered by Finnish social security, the social security charges are imposed. If the employee is on an assignment, an "insurance salary" is set for social security purposes. Insurance salary is a computation amount used to calculate the amount of employer and employee social security contributions payable.
It should be noted that, if a tax treaty applies and the other country is prevented under the treaty's provisions from taxing the income, the income is fully taxable in Finland. In such cases, double taxation is eliminated by applying the provisions of the tax treaty.

6.2.4. Deductions and Allowances 
Deductions are taken from earned income and capital income separately.
 Deductions from earned income   
The tax assessment for earned income involves first subtracting the tax-deductible amounts from the gross income, then assessing the remaining amount according to the progressive scale of state taxation. Individuals can deduct certain costs associated with income-generating activities. Deductions are items that reduce total income and therefore reduce overall tax liability.
The so-called natural deductions consist of the schematic deduction for acquiring income, the deduction for commuting costs between home and work, the deduction for paying trade union membership fees, membership fees of an unemployment fund, and other costs relating to generating or maintaining income. Nevertheless, in the case of wage income, there is a schematic deduction for acquiring income, so only amounts in excess of the schematic deduction will qualify. Net taxable earned income is calculated from gross earned income minus the natural deductions.
The net taxable earned-income amount can further be reduced by deducting mandatory pension contributions, additional pension contributions, the deduction for a reduced capacity to pay tax, the pension income deductions concerning state tax and municipal tax, and additionally for municipal taxation only: deductions for disability, for study grants, earnings, etc.
 Deduction from capital income   
Under the Income Tax Act, the costs of acquiring and preserving of capital income are tax deductible. Examples of those are the costs associated with acquiring capital income, costs associated with acquiring an aftermarket bonus, losing money as a foreign-currency loss on certain loans, repayments of shareholder borrowing, forestry deductions and payments of interest. The contributions for voluntary pension insurance contracts are usually deductible against capital income.
 Tax credits 
Some tax deductions involve reduction of the amount of tax to be paid: e.g., the credit for the obligation to pay child maintenance. A further credit for domestic help reduces the state income tax on earned income and capital income. If the taxpayer does not have enough state tax to make the full tax credit possible, the remaining amount can be credited against municipal tax, healthcare payment and church tax.
 Interest on loans 
A taxpayer who has borrowed money is eligible for a tax deduction when paying interest on certain loans. Generally, the payment of interest relates to a loan acquiring capital income. As a main rule, the interest paid on a loan is deductible from capital income. It should be noted, however, that a loan may also relate to acquiring earned income, in which case the deduction will be from earned income.
With effect from 2023, home loan interest expenditure is not deductable. However, interest expenses for loans relating to residential-property investment remain deductible. 
Generally, when calculating capital gain the acquisition costs and sales costs are deducted from the sales price. A minimum deduction of 20 percent of the sales price is applied when calculating the taxable capital gain. If the property has been held for at least 10 years, the minimum deduction is 40 percent.
Capital losses are deducted from all capital income.

6.3. Main Rates and Bands 

6.3.1. Individual Tax Rates 
In tax year 2024, the following rates and bands of national personal income tax apply:
•	for the first income band, the state tax is 12.64 percent up to 20,500 euros;
•	for the second income band, the state tax is 2,591.20 euros for the first 20,500 euros, plus 19 percent on the excess up to 30,500 euros;
•	for the third income band, the state tax is 4,491.20 euros for the first 30,500 euros, plus 30.25 percent on the excess up to 50,400 euros;
•	for the fourth income band, the state tax is 10,510.95 euros for the first 50,400 euros, plus 34 percent on the excess up to 88,200 euros;
•	for the fifth income band, the state tax is 23,362.95 euros for the first 88,200 euros, plus 42 percent on the excess up to 150,000 euros;
•	for the sixth and final income band, the state tax is 49,318.95 euros for the first 150,000 euros, plus 44 percent on the excess.
In tax year 2023, the following rates and bands of national personal income tax applied: 
###$$$ for the first income band, the state tax was 12.64 percent up to 19,900 euros;
###$$$ for the second income band, the state tax was 2,515.36 euros for the first 19,900 euros, plus 19 percent on the excess up to 29,700 euros;
###$$$ for the third income band, the state tax was 4,377.36 euros for the first 29,700 euros, plus 30.25 percent on the excess up to 49,000 euros;
###$$$ for the fourth income band, the state tax was 10,215.61 euros for the first 49,000 euros, plus 34 percent on the excess up to 85,800 euros; and
###$$$ for the fifth and final income band, the state tax was 22,727.61 euros for the first 85,800 euros, plus 44 percent on the excess.

In addition to the national personal income tax, there is a municipal tax of approximately 4.4 percent to 19.7 percent (4.36 percent to 10.86 percent in 2023) depending on the municipality and a church tax (approximately 1 percent to 2.25 percent).
Capital gain arising from investments that are treated as capital income is taxed as follows: 1) a flat rate of 30 percent for income from 0 up to 30,000 euros; and 2) a flat rate of 34 percent for income exceeding 30,000 euros.
 Nonresidents 
Nonresidents' taxation is carried out either by withholding a flat-rate source tax on all income, or by performing a similar progressive tax assessment as is done for Finnish residents, in which case the rate of tax depends on the size of the income.
If a company, treated as a Finnish employer, is paying a nonresident individual as an employee, the employer must withhold 35 percent as source tax on a gross basis (i.e., no allowance is granted for expenditure incurred in deriving the income), subject to a standard monthly allowance. Aside from tax, the employer must also withhold social security and insurance contributions (see [6.6.2]Section 6.6.2[end]) unless the employee has a certificate (such as an A1 Certificate) showing that coverage by the social insurance system of a foreign country is still valid. A tax relief for key employees in Finland grants, under certain conditions, a lower tax at source of 32 percent.
If the taxpayer is a performing artist or athlete, a final tax at the source of 15 percent is collected on the income earned in Finland, based on personal activity. A nonresident employee from a country within the EEA or from a country with a tax information exchange treaty can request progressive taxation on the same basis as a Finnish resident.
Generally, services income derived by a nonresident individual is subject to Finnish taxation (by way of assessment) only if it is derived from a business or profession carried on in Finland. In practice, a nonresident individual is deemed to carry on business in Finland if he or she has a fixed place of business, such as an office or a workshop, for that purpose in Finland, and if that fixed place is used for commercial purposes. However, Finnish-source business profits of a nonresident may be taxed in Finland in a nontreaty situation even if there is no PE in Finland.

6.3.2. Individual Returns, Filing Dates, and Payment 
In most cases, taxpayers receive a pre-completed tax return in March or April of the year following the tax year. The taxpayer is not required to do anything if there are no corrections or additions. If corrections or additions are necessary, the revised return must be filed with the tax authority. The filing deadlines are in April and May, with the precise deadline depending on individual circumstances. Spouses must file tax returns separately.
Income tax returns can be filed on paper or electronically.
An extension is possible if special, qualified reasons exist. The last possible date to file the tax return is case-specific.
An individual taxpayer has the right to make a supplementary payment of tax by the end of January in order to avoid unnecessary interest and penalties. A supplementary payment of tax may be made if it seems that the amount of taxes withheld during the calendar year will not cover the taxpayer's liability.
A foreign individual working in Finland for a period of up to six months has final tax withheld from wages paid by a Finnish employer at the rate of 35 percent (or 32 percent in the case of key employees). Where such an individual is a resident of a country within the European Economic Area, or a country that has a bilateral tax treaty with Finland, they may instead request taxation under the progressive scale and be taxed as a taxpayer living permanently in Finland. A foreign individual working in Finland continuously for a period of over six months is taxed under the progressive scale in the same way as a taxpayer resident in Finland.

6.4. Dividends 

6.4.1. Domestic Corporations 
Taxation of dividend income from domestic corporations depends on whether dividends are from a publicly traded limited liability company, or any other, unlisted limited liability company.
Generally, Finnish-resident individuals are taxed at the rates for capital income (see [6.3.1]Section 6.3.1[end]) on 85 percent of dividends paid by a publicly traded domestic company. The remaining 15 percent is tax-exempt.
A dividend paid by a nonlisted company to a Finnish resident individual may be split to be taxed partly as capital income and partly as earned income: 
•	25 percent of the dividends of a nonlisted company is taxable capital income insofar as the amount of dividends corresponds to an 8 percent annual return calculated on the mathematical value of the share, up to a maximum of 150,000 euros per payee; 
•	85 percent of the dividends exceeding the 150,000 euros threshold (but not exceeding the above-mentioned 8 percent) is deemed taxable capital income; and 
•	75 percent of the portion exceeding the amount corresponding to an annual return of 8 percent is deemed taxable earned income.
The reduced rate does not depend on the individual's level of share ownership.
Subject to treaty, there is a 30 percent withholding rate on dividends paid to a nonresident individual. However, dividends paid to a nonresident living in another EU Member State or an EEA country are taxable under the rules applying to resident individuals if the Finnish withholding tax is not fully creditable in the country of residence.

6.4.2. Foreign Corporations 
Individuals are taxed on receipt of dividends from a foreign corporation.
Under certain conditions, if a Finnish resident receives dividends from corporations that are resident in another EU Member State or a state with a tax treaty with Finland, the tax assessment will be no different from that of dividends from Finnish companies or payer, if: 
###$$$ the dividend distributing entity is a company covered by the Parent-Subsidiary Directive; or
###$$$ the dividend distributing entity is a resident of a European Economic Area State, which considers that the entity is a resident of that state for tax purposes and the dividend distributing entity is liable to at least a 10 percent tax on the profits from which the dividend is distributed, without the possibility of an option or of being exempt; or
###$$$ the state is a tax treaty state and the tax treaty is applied to the dividend. The minimum level of 10 percent tax, however, applies also in the case of the tax treaty states. (See [6.4.1]Section 6.4.1[end]).

All other dividends are taxed as earned income.
Finland applies the credit method for eliminating double taxation with respect to dividends both in nontreaty and treaty situations. Any income tax paid to a foreign state will be fully creditable even if a part of the dividend would be regarded as exempt from tax if the company were Finnish. However, the amount of credit will always correspond to the theoretical amount of tax that would be paid if the company were Finnish.

6.5. Interest 

6.5.1. Domestic Borrowers 
Finnish individuals are taxed on receipt of interest from a domestic bank account or bond.
The tax rate for interest income is 30 percent or 34 percent if the annual capital income exceeds 30,000 euros.
Tax is withheld from interest paid on bank deposits and bonds. The tax at source withheld by the bank or bond issuer is a final tax and an individual taxpayer does not report income from interest on a tax return.
A 30 percent withholding tax applies to interest paid to nonresident individuals (unless an applicable tax treaty provides a lower rate), but interest payments to nonresidents are, in practice, normally exempt from tax.

6.5.2. Foreign Borrowers 
Individuals are taxed on receipt of foreign interest from a foreign corporation. The interest is taxed as capital income.
There are no exceptions.
Finland eliminates international double taxation using the credit method.

6.6. Social Security/National Insurance Payments 

6.6.1. Employer Tax or Contribution 
Statutory social insurance contributions in Finland include the employer's health insurance contribution, earnings-related pension insurance, unemployment insurance contribution, accident insurance contribution and group life insurance contribution.
In 2024, the employer's health insurance contribution equals 1.16 percent of the sum total of the payroll. Employers must pay health insurance contributions for employees aged from 16 to 67 years.
An employer's earnings-related pension insurance contribution is on average 17.34 percent. The amount is affected by various discounts and credits. Employers must pay earnings-related pension insurance for employees aged from 17 to 68.
The amount of the accident insurance contribution and group life insurance contribution varies depending on the nature of employers.
The employer's unemployment insurance contribution is calculated as follows: 
###$$$ for paid wages up to 2,337,000 euros per year — 0.27 percent; and
###$$$ for paid wages exceeding 2,337,000 euros per year — 1.09 percent.

The unemployment insurance contribution is paid in respect of employees aged from 18 to 64 years old.

6.6.2. Employee Tax or Contribution 
In 2024, a Finnish employee's share of the statutory employment pension insurance contribution is as follows: 
###$$$ age 17 years to 52 years — 7.15 percent;
###$$$ age 53 years to 62 years — 8.65 percent; and
###$$$ age 63 years to 67 years — 7.15 percent.

An employee's share of the unemployment insurance contribution is 0.79 percent. The unemployment insurance contribution is withheld in respect of employees aged from 18 to 64 years old.
The employee's health insurance contribution consists of two components: (i) a health care contribution of 0.51 percent, and (ii) a daily allowance contribution of 1.01 percent. Where income is less than 16,499 euros, the daily allowance contribution is 0 percent.
In contrast to other contributions, an employee's health insurance contributions are included in the withholding rate. Thus, no additional withholding is necessary.

6.6.3. Employee Tax Collection Mechanism 
In general, a Finnish employer is obliged to withhold tax on wage payments to employees.
There is no option for the employee to pay this tax directly.
There is no option for the employee to elect out of the national system.

6.7. Royalties and Rents 

6.7.1. Domestic Licensors 
Income from rent from a domestic or a foreign use of property is taxed as capital income. Income from royalties may be deemed as earned income or capital income depending on the situation.
Royalty income is taxed in Finland at normal rates or a reduced rate if a relevant treaty applies.
There is no withholding tax on rent from domestic use of property. Royalties may be deemed as earned income or capital income for the individual and the obligations depend on applicable income.

6.7.2. Foreign Licensors 
Finland imposes taxation on royalties or rent from a domestic use of property from Finland when paid to a nonresident recipient.
Royalty income is taxed at a normal or reduced rate based on the applicable tax treaty.
Under Finnish law there is a 30 percent withholding tax on royalties paid to nonresident individuals. It is a final tax, but may be credited in the home country of the recipient. However, tax treaties limit the source state taxing right of Finland substantially.

7. Transfer Pricing Policies 

7.1. Application 
Transfer pricing rules apply to both domestic and international related-party transactions. The arm's-length principle must be applied in all transactions, both domestic and international, and between a company and its PE. Monitoring is accomplished through tax audits instead of standard annual assessments.

7.2. Permissible Pricing Methods 
In general, the permissible pricing methods are in accordance with the OECD guidelines.

7.3. Penalties for Improper Pricing 
If the arm's-length principle is not followed, profits and losses of the companies may be adjusted as if the arm's-length principle was applied. In addition, if the hidden profit transfer takes place in a dividend distributing relationship from a subsidiary to its parent company, the hidden profit transfer may constitute a disguised dividend. Further, if an intragroup transaction includes clear tax avoidance purpose the general tax avoidance provision may be applied. Also, a surtax penalty may be imposed on the taxpayer.

7.4. Advance Rulings or Pricing Agreements 
In a domestic situation a company may apply for an advance ruling from the tax authorities relating to the income tax. Finland does not have regulations on APA procedure, but this kind of advance pricing agreement may be made based on the tax treaties currently in force. However, there are no regulations to validate the APA to be accomplished in due course in the mutual agreement procedure.
The tax treaties include a provision of mutual agreement procedure, based on which international double taxation may be avoided. In addition, the EU Arbitration Convention between EU Member States establishes a procedure to resolve disputes where double taxation occurs between enterprises of different Member States as a result of an upward adjustment of profits of an enterprise of one Member State. However, currently there are no regulations in Finland on execution of a decision of competent Finnish tax authority.
Finland has enacted legislation to implement the provisions of Directive 2015/2376/EU (DAC3) (amending Directive 2011/16/EU (DAC)) on the automatic exchange of advance cross-border tax rulings and advance pricing arrangements within the EU. Finland exchanges information automatically on advance cross-border tax rulings and advance pricing agreements in conformity with this EU Directive.

7.5. Documentation 
The Finnish transfer pricing rules contain documentation obligations regarding cross-border transactions. However, the documentation requirement does not apply to small and medium-sized companies, i.e., companies with (i) fewer than 250 employees, (ii) maximum turnover of 50 million euros or total of the balance sheet maximum of 43 million euros, and (iii) meeting certain other characteristics as laid down in the Commission Recommendation 2003/361/EC. In practice, the limits are compared to the group balance sheet and income statement of the ultimate parent company. Thus, even a small Finnish company is often subject to documentation obligations if it belongs to a larger multinational group.
In brief, the transfer pricing documentation must contain a master file with the following information concerning the group 
(1) organizational structure;
(2) description of business or businesses;
(3) description of activities relating to intangibles;
(4) intragroup financial activities;
(5) annual report or equivalent information; and
(6) information on cross-border tax rulings and advance pricing arrangements.

Additionally, the transfer pricing documentation must contain a local file with the following information concerning the reporting entity itself: 
(1) description of organizational and management structure;
(2) description of business or businesses;
(3) description of associated enterprises;
(4) information on transactions between associated enterprises;
(5) functional analysis of transactions between associated enterprises;
(6) comparability analysis, including information on comparables;
(7) description of applied pricing policy;
(8) annual report or equivalent information; and
(9) any such tax rulings and arrangements concerning transactions between associated enterprises that are not issued or contracted by Finland.

There is no specific time requirement for documentation. However, pursuant to the Finnish Act on Assessment Procedure §14c, taxpayers should submit the documentation for a specific fiscal year within 60 days from a request by the tax authorities, and at the earliest six months after the end of the relevant accounting period. Any additional explanations concerning the documentation must be submitted within 90 days from request.
Furthermore, Country-by-Country (CbC) reporting obligations, developed under Action 13 of the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan, apply to companies belonging to a multinational group with a consolidated turnover of at least 750 million euros. Only one group company (generally the ultimate parent company) should submit the CbC report for the entire group. In brief, the CbC report should contain the following information: 
(1) amount of revenue;
(2) profit (loss) before income tax;
(3) income tax and withholding tax paid and accrued;
(4) stated capital;
(5) accumulated earnings;
(6) number of employees; and
(7) tangible assets other than cash or cash equivalents.

The CbC report should also include an identification of each group entity setting out, e.g., the nature of the main business activities of the entities.
National implementation of the CbC reporting obligations was carried out in Finland in accordance with BEPS Action 13 and EU Directive 2016/881/EU ("DAC4").
Finland is a signatory to the Multilateral Competent Authority Agreement on the Automatic Exchange of CbC Reports.
Public CbC Reporting
The Law on amending the Accounting Act (238/2024) transposes into national law, with effect from financial years commencing on or after June 22, 2024, Directive (EU) 2021/2101 of November 24, 2021, amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches. Subject to certain exclusions, the directive imposes a public CbC reporting obligation on certain categories of undertaking, including:
• an EU-based ultimate parent undertaking of a group; and
• certain EU-based subsidiaries or branches of a group whose ultimate parent undertaking is based outside the EU.
In both cases, this is subject to the requirement that the group's consolidated revenue, as reflected in its consolidated financial statements, exceeded 750 million euros in each of the previous two financial years. The reporting obligation applies to the second of those years.
The report must be published within 12 months following the closing date of the financial year for which it is drawn up. The report must be published on the entity’s website where it needs to remain available for an uninterrupted period of five years.
As permitted by the directive, the Finnish legislation includes an option for reporting entities to defer, for up to five years from the publication of the report in which the relevant information would otherwise have been included, the reporting of information that would cause serious financial harm to the entities to which the report relates. This option does not apply to information relating to jurisdictions included in the EU list of non-cooperative jurisdictions for tax purposes or the EU list of jurisdictions that have committed to implement reforms to comply with international tax standards.

8. Anti-Avoidance Provisions 

8.1. General Anti-Avoidance Provisions 
There is a general anti-avoidance statutory provision in the Act on Tax Procedure in Finland that may be applied to both domestic and cross-border situations. This principle states that if there is no or inadequate business reason for a transaction, the transaction will be void for tax purposes. Tax is then assessed according to the transaction's actual character. The legal form of the transaction may still be valid for other purposes, e.g., corporation law.
In addition to the general anti-avoidance provision there are also some other provisions aiming to prevent tax avoidance; for example, there is a provision on hidden profit distributions and constructive dividends applicable to cross-border situations, and some anti-avoidance provisions applicable to specific situations, such as denying the preferential tax regime applicable to mergers, etc.
A dividend is taxable income to the extent that there is an arrangement or series of arrangements, whose main purpose, or one of the main purposes of tax avoidance.
In addition to the anti-avoidance provisions in domestic tax legislation, there are also anti-avoidance provisions built into tax treaties, which are applied in Finland.
 DAC6: Mandatory disclosure rules 
Finland has enacted Law 1567/20192 transposing the mandatory disclosure requirements introduced under Directive 2018/822/EU (DAC6) (amending Directive 2011/16/EU (DAC)) into national legislation. The legislation entered into force on January 1, 2020 and applies to reportable cross-border arrangements from July 1, 2020, with retrospective effect from June 25, 2018.3
Under the rules, service providers (a term that corresponds to "intermediaries" in DAC6) and, in some cases, the relevant taxpayer itself, are obliged to notify the tax authority of reportable cross-border tax planning arrangements for which the EU Member States will then automatically exchange information. An arrangement must be reported to the tax administration within 30 days from the date it is made available for execution, it is ready for implementation, or the first phase has been completed.4
A service provider who has planned a marketable arrangement (i.e., non-bespoke arrangement) and issued a first notification, or who markets a marketable arrangement planned by another service provider, is obliged to notify the tax authority every three months of certain information on the arrangement that has become available since the previous notification.
The maximum penalty for failure to fulfill the reporting obligation is 15,000 euros, depending on the seriousness of the breach.
The Finnish tax authority has published online guidance on reportable cross-border arrangements.
Planning Point: Practitioners should note that the Finnish legislation follows the text of the DAC6 Directive, with the same hallmarks and the same application to cross-border arrangements only.
 DAC7: Reporting obligations for digital platform operators 
Finland has enacted Law No. 1267/2022 which transposes Article 1(8) of Directive 2021/514/EU (DAC7) (amending Directive 2011/16/EU (DAC)) and introduces mandatory reporting rules for digital platform operators. Primarily, the directive extends tax transparency rules to digital platforms by requiring (i) reporting platform operators to collect and report prescribed information on reportable sellers using their platforms for certain commercial activities, and (ii) EU Member States to automatically exchange this information.
Finland has largely followed the wording of the DAC7 Directive. The DAC7 Directive replaces the former domestic law obligation to submit an annual information return on intermediated transport services and rental income.
Reporting Platform Operators: The legislation provides for the collection and reporting to the Finnish tax authority of certain information by digital platform operators in respect of sellers of goods and services using their platforms.
A platform is defined as any software, including websites and mobile applications, which allows sellers to connect to other users to carry out a relevant commercial activity. However, the definition does not include platforms that allow only (i) the processing of payments, (ii) listing or advertising by users or (iii) the redirection or transfer of users to a platform.
Reporting applies to operators of digital platforms who are tax resident in Finland, incorporated or managed in Finland, or have a permanent establishment in Finland, provided that the platform is engaged in a relevant commercial activity. A platform operator that is tax resident, incorporated or managed, or has a permanent establishment in another EU Member State, can elect to register and report in that other Member State.
Non-EU platform operators must also report to the Finnish tax authority if they are registered in Finland and facilitate relevant activities of EU sellers or the rental of immoveable property located in a Member State.
Relevant Activities: The relevant activities that trigger an obligation to report are: 
###$$$ the rental of immoveable property;
###$$$ the provision of a personal service (time or task-based work);
###$$$ the sale of goods (tangible property); and
###$$$ the rental of any mode of transport.

For the reporting obligation to apply, the activity must be carried out for consideration and may be cross-border or domestic.
Reportable Sellers: A reportable seller is an EU resident individual, company or legal arrangement, registered on the platform and carrying out a relevant activity. Non-EU resident platform users renting out immoveable property located in an EU Member State are also reportable sellers.
Government and publicly traded entities are excluded from reporting. So too are casual sellers of goods for which the platform has facilitated less than 30 sales and for which the total consideration paid does not exceed 2,000 euros during a reporting period. An exclusion also applies to sellers engaged in high frequency renting of immoveable property. To qualify, there must be more than 2,000 relevant transactions during a reporting period.
Information to be Reported: From January 1, 2023, reporting platform operators must collect prescribed information on non-excluded sellers carrying out a relevant activity and identify reportable sellers. Due diligence provisions require the platform operator to verify the reliability of the information gathered.
The information to be disclosed to the Finnish tax authority includes a reportable seller's identity, EU Member State of residence, financial account details, tax identification number ("TIN"), VAT/business registration numbers, consideration paid or credited per quarter, and any fees, commissions or taxes withheld by the reporting platform operator.
Additional information is required to be reported in the case of rental of immovable property.
Reporting Mechanics: Reportable information must be submitted to the Finnish tax authority no later than January 31 of the year following the calendar year in which a reportable seller is identified. 
Exchange of reported information by EU Member States is required within two months following the end of the reporting period.
 Anti-hybrid rules 
Finland has enacted Law 1567/20195 which implements the hybrid mismatch rules contained in Directive 2016/1164/EU (the Anti-Tax Avoidance Directive) (ATAD) as amended by Directive 2017/952/EU as regards differences in tax treatment with third countries. The legislation applies to companies, partnerships and limited partnerships, and restricts the deductibility of expenditure, or the tax exemption of income, in the case of transactions between related parties and transactions relating to structured arrangements.
With effect from January 1, 2022, the Finnish legislation includes provisions on reverse hybrid mismatches. According to the rules, nonresident partners of Finnish business partnerships are liable to pay tax on the income of a reverse hybrid entity in Finland if the conditions set out in the tax legislation are met. In broad terms, a reverse hybrid entity refers to a situation where a Finnish business partnership, which is treated as a tax-transparent entity under Finnish law, is regarded as a separate taxpayer under the laws of another state.

8.2. Thin Capitalization/Other Interest Deductibility Rules 
Finland does not have any thin capitalization rules.
With effect from January 1, 2019, the Finnish interest deductibility rules have been amended as part of the implementation of the EU Anti-Tax Avoidance Directive (Directive 2016/1164/EU) (ATAD) and net interest expenses are not tax deductible in certain circumstances.
Deductibility of interest expenses for intra-group loans is restricted to 25 percent of fiscal EBITDA. Excess interest can be carried forward to future years. The limitation rules do not apply if either of the following conditions is met: 
###$$$ net annual interest expense (including both intragroup and nonrelated party interest) does not exceed 500,000 euros; or
###$$$ the Finnish entity's equity-to-gross-assets ratio is at least equal to the consolidated ratio for the group (balance sheet exemption).

The balance sheet exemption is not applicable in situations where a party with significant holdings (at least 10 percent) has financed the group. In this situation, the consolidated balance sheet forming the basis for comparison is adjusted so that debt from the shareholder is considered equity in the balance sheet comparison, thereby increasing the equity-to-asset ratio of the group.
Under amendments introduced by Law 1014/2022 with effect from January 1, 2023, the balance sheet exemption is also inapplicable if the consolidated balance sheet indicates that the amount of interest paid to parties owning a significant part of the group's shares is at least 20 percent of all interest paid outside the group. Law 1014/13 further provides, with retrospective effect from tax year 2019, that a privately owned entity carrying out a long-term public infrastructure project commissioned by a public entity may deduct otherwise non-deductible net interest expenses paid to non-associated parties.
Net interest expenses between nonrelated parties exceeding 3 million euros are not tax deductible.

8.3. Controlled Foreign Company (CFC) Rules 
A Finnish resident corporation may be taxed on its share of profits of a foreign entity, even if those profits have not been distributed. This regime applies when Finnish corporate entities or resident individuals subject to unlimited tax liability in Finland control a foreign corporate entity. With effect from January 1, 2019, the Finnish CFC rules have been amended as part of the implementation of the EU Anti-Tax Avoidance Directive (Directive 2016/1164/EU) (ATAD).
The threshold of control for an entity to qualify as a CFC is 25 percent ownership of share capital or voting rights, or entitlement to 25 percent of profits of that entity. With effect from January 1, 2019, the calculation also takes into account direct or indirect holdings in the CFC by Finnish and non-Finnish dependent entities.
In order for a foreign corporate entity or a PE to qualify as a controlled foreign corporation under the Finnish CFC regime, its actual income tax burden in its state of residence must be less than three-fifths of the tax burden of a Finnish corporate entity resident in Finland. The general corporate income tax burden in Finland is 20 percent, thus the CFC regime does not apply if the foreign taxes gross up to at least 12 percent of the total profit.
 Companies resident within the EEA   
CFC legislation does not apply if the following conditions are met: 
###$$$ the entity is resident in a member state of the EEA; and
###$$$ the controlled entity is actually established in the host state and, objectively, carries out genuine economic activities there.

 Companies resident outside of the EEA   
CFC legislation does not apply if the CFC mainly receives its profits, e.g., from industrial production activities, corresponding other production activities, shipping activities, or sales or marketing activities that serve the above activities and the entity has enough substance to carry out the business activities.

9. Other Taxes 

9.1. Payroll Taxes 
There are no payroll taxes in Finland. For tax to be withheld by employers, see Section 6.

9.2. Capital Taxes (Capital Duties) 
There are no taxes on capital in Finland.

9.3. Property Taxes 

9.3.1. Transfer Taxes, Including Real Property Transactions 
In general, a transferee of real property situated in Finland or of securities in Finnish companies is liable to pay transfer tax under the Finnish Transfer Tax Act. In the case of real property, the transfer tax rate is 3 percent of the transfer price, and in the case of securities in a real estate company or a housing company, the rate is 1.5 percent. The transfer tax rate for shares in other typers of companies is also 1.5 percent. However, transfer of securities is tax exempt under certain conditions if it takes place through the Helsinki Stock Exchange or if the securities have been admitted to trading on a regulated market within an EEA member state or in a non-EEA state that recognizes the provision of executive assistance between competent authorities. Furthermore, the exemption covers securities that have been admitted to trading on multilateral trading facilities.
In addition, the transfer of securities is not subject to transfer tax if neither the transferee nor the transferor is resident in Finland. However, the transfer of Finnish real estate or the shares in a Finnish housing or real estate company is always subject to transfer tax.
There is no transfer tax payable on an asset obtained as a gift or inheritance from a spouse. 
The transfer tax for real estate transactions must be paid, and a transfer tax notification submitted, within six months of signing the transfer deed and the tax on equity and securities transactions within two months of signing the deed of sale.
The sale of apartments abroad is subject to taxation in Finland despite being subject to the same tax in the state where the property is located; double taxation may, however, be avoided in cases where Finland has entered into a double taxation agreement with the country where the dwelling is located, by using either the credit method (such as in treaties with the Nordic states) or the exemption method (such as in treaties with Spain, Portugal, France and Egypt), as provided in the treaty.

9.3.2. Real Property Taxes 
Real property situated in Finland is subject to real estate tax unless a particular exemption applies. The revenue goes to the municipality where the property or building is situated. Water areas and land used in forestry or agriculture are exempted.
Real estate tax is payable by those who own taxable property at the beginning of the calendar year. The tax is charged on the taxable value of property at rates set annually by each municipality (within a range set by statute). 
With effect from January 1, 2024, the ranges, within which real estate tax rates must be set, are as follows: 
•	general real estate tax rate on land — 1.3 percent to 2 percent;
•	tax rate for permanently used residential buildings — 0.41 percent to 1 percent;
•	tax rate for other residential buildings — 0.93 percent to 2 percent;
•	general real estate tax rate for buildings — 0.93 percent to 2 percent; and
•	tax rate of unbuilt site — 2 percent to 6 percent.

9.3.3. Taxes on Movable Property 
There is no personal property tax in Finland.

9.3.4. Fixed Asset Taxes 
There is no fixed asset tax in Finland.

9.4. Miscellaneous Taxes 
Finland is a signatory to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, issued by the OECD on October 8, 2021. 
The first element of that solution, Pillar One, includes the creation of a new taxing right for market jurisdictions, known as Amount A. Only multinational entities with global turnover exceeding 20 billion euros and pre-tax profitability exceeding 10 percent will fall within the scope of the Amount A taxing right. Pillar One will be implemented through a multilateral convention (MLC) that is currently being developed and through correlative changes to domestic law. The MLC will require its parties to remove all digital services taxes and other relevant similar measures in respect of all companies.
The second element of that solution, Pillar Two, seeks to limit corporate tax competition between jurisdictions by implementing an effective 15 percent global minimum corporate tax rate for large multinational entities.
Implementation of Pillar Two
EU Pillar Two Directive
Within the EU, the global minimum tax provisions of Pillar Two are being implemented through the EU Directive on minimum taxation (EU Directive 2022/2523) ("the Directive"), published in the EU Official Journal on December 22, 2022. The Directive introduces the Pillar Two "top-up" tax (i.e., a tax applied at a rate equivalent to the difference between an effective tax rate (ETR) of 15 percent and the actual ETR for a jurisdiction). Subject to various exclusions, it applies to groups which have constituent entities (CEs) in an EU Member State and which have annual consolidated revenues of at least 750 million euros in at least two of the four fiscal years immediately preceding the relevant fiscal year. Both multinational enterprise (MNE) groups and domestic groups fall within the remit of the Directive.
The Directive includes the following elements:
Income Inclusion Rule (IIR) — The Directive implements the top-up tax through the introduction of the IIR applicable to fiscal years commencing from December 31, 2023. The IIR requires ultimate parent entities (UPEs) of affected MNE groups located in a Member State to pay a top-up tax if the ETR on their foreign operations is below 15 percent. This is calculated on a jurisdiction-by-jurisdiction basis. Additionally, a UPE located in a low-tax Member State is subject to the IIR in respect of itself and of all low-taxed CE's of the group located in that Member State.
Qualified Domestic Top-up Tax (QDTT) — The Directive permits Member States to implement a QDTT applicable to fiscal years commencing from December 31, 2023. Under the QDTT, a relevant group's CEs, located in a Member State, must pay a top-up tax in that state where the effective tax rate on their domestic operations is less than 15 percent. A Member State must make an election if it wishes the QDTT to apply.
Undertaxed Profits Rule (UTPR) — The Directive contains a UTPR (i.e., a "backstop" rule that enables a jurisdiction to require the resident CE of an MNE group to account for any top-up tax that has not otherwise been collected through an IIR or a QDTT), applicable to fiscal years commencing from December 31, 2024. The UTPR is applicable when the UPE of an MNE group is located outside the EU in a jurisdiction that does not apply a qualified IIR or is an excluded entity. It also applies when the UPE is located in a country outside the EU with an ETR below 15 percent. 
Under the Directive, the UTPR can be applied either through (i) the denial of a deduction, or (ii) an equivalent adjustment.
Safe Harbors — The Directive requires Member States to ensure that, at the election of the filing CE, the top-up tax due from a group in a jurisdiction is deemed to be zero for a fiscal year if the effective level of taxation of the CEs located in that jurisdiction fulfils the conditions of a qualifying international agreement on safe harbors (i.e., an international set of rules and conditions to which all Member States have consented and which grants groups within the scope of the Directive the possibility of electing to benefit from one or more safe harbors for a jurisdiction).
Penalties — The Directive requires Member States to lay down effective, proportionate and dissuasive penalties for infringements of national provisions adopted under the Directive.
The Directive largely follows the Global Anti-Base Erosion Model Rules (GloBE Rules) published by the OECD, but with certain variations to ensure compliance with EU law, including: 
•	Application to large-scale domestic groups — Unlike the GloBE Rules, the Directive applies not only to MNE groups, but also to domestic groups that meet the turnover threshold. 
•	Application to domestic CEs — Where a relevant group's UPE is located in a low-tax Member State, it is subject to the IIR in respect of itself and all low-taxed CEs of the group located in that Member State for the fiscal year. In contrast, the GloBE Rules apply the IIR only to the low-taxed income of a group's foreign CEs.
•	Delayed application of the IIR and the UTPR — Member States with no more than 12 UPEs of groups within the scope of the Directive may elect to defer application of the IIR and UTPR for six consecutive fiscal years beginning from December 31, 2023. If the Member State making the election is low-taxed, then the other Member States must apply the UTPR to their CE's of such groups for fiscal years beginning from December 31, 2023. 
Member States were required to bring into force the laws, regulations and administrative provisions necessary to comply with the Directive by December 31, 2023, with the measures envisaged generally to apply to financial years beginning on or after that date.
Finland's implementation of Pillar Two directive
Finland has implemented the Directive through the Law on Minimum Tax for Large Corporations (1308/2023). The Finnish legislation generally follows the Directive.
The IIR applies in Finland for accounting periods commencing from December 31, 2023.
The UTPR generally applies in Finland for accounting periods beginning from December 31, 2024. However, where the UPE of an MNE group is located in a Member State that has elected for delayed application of the IIR and UTPR, Finland will apply the UTPR for accounting periods beginning from December 31, 2023. 
Finland has adopted a QDTT. This domestic top-up tax is calculated in a similar way to taxes payable under the accrual rule. The tax rate under the Finnish QDTT is 15 percent. The QDTT applies for accounting periods commencing from December 31, 2023.
Finland has implemented the transitional CbCR safe harbor.
A relevant group’s CE, located in Finland, must file an annual top-up tax information return, unless the return is filed (i) by a designated local entity, or (ii) by the UPE or a designated group filing entity in another jurisdiction with which Finland has a qualifying competent authority agreement. The return must be filed no later than 15 months after the end of the relevant fiscal year (extended to 18 months in the first year that a group falls within the scope of application of the Directive with respect to Finland).
Failure to comply with the reporting obligations may result in a late filing fee, or a tax increase based on a percentage of the under-paid top-up tax. In the case of an unlawful avoidance or attempted avoidance of tax, the matter may be subject to criminal proceedings. 
For further information on the Two-Pillar Solution, see the Bloomberg Tax "OECD Two-Pillar Solution Global Tax Agreement Watch".
Planning Point: 
The top-up tax information return for tax year 2024 must be filed by June 30, 2026. Questions regarding Finland's implementation of Pillar Two may be submitted to the tax authority at the following e-mail address: Minimivero(a)vero.fi
Exit Tax 
With effect from January 1, 2020, Finland has implemented Law 1577/2019 on exit taxation which transposes the requirements of the EU Anti-Tax Avoidance Directive (Directive 2016/1164/EU) (ATAD) into national law.6 The provisions on exit taxation correspond to the minimum standard established in ATAD. The provisions include a definition of a so-called exit value which is taxable income in the case of an exit.
The application of exit taxation on transferred assets takes place if (i) a taxpayer transfers assets from a PE located in Finland to a head office/PE located in another country; (ii) assets located in a Finnish head office are transferred to a PE in another country; (iii) the business operations of a Finnish PE are transferred out of Finland; or (iv) a Finnish tax-resident company transfers its domicile to another state, except for assets that factually remain in a Finnish PE.7
A deferral of payment of tax for a period of up to five years is available for transfers concerning EU/EEA countries.
 Inheritance Tax 
Inheritance tax is imposed by the state. Tax on inheritances is imposed on the individual share of each beneficiary. The applicable tax rate depends on the relationship between the deceased person and the beneficiary (relationships are divided into two classes). There is no estate tax.
No inheritance tax will be payable if the total of inherited assets is valued below 20,000 euros. Liability to inheritance tax covers any property, if the deceased person or the heir or the receiver of a bequest is a resident of Finland. If both the deceased and the heir are not resident in Finland, tax liability only concerns real property situated in Finland, and shares in a company in which more than 50 percent of the assets consist of Finnish real property.
To avoid double taxation, any possible inheritance tax paid in a foreign country is credited against Finnish tax, unless the foreign tax is imposed on real property situated in Finland.
 Gift Tax 
Gift tax is imposed by the state and follows the same principles as inheritance tax. Any gift worth at least 5,000 euros is subject to gift tax. In gift taxation, gifts from the same donor within three years are accumulated to determine the amount of tax. Joint recipients may file a single gift tax declaration, and all gift recipients are jointly and severally liable for the payment of tax.
 Excise Duty 
Excise duty is imposed in Finland on various items, including soft drinks, alcoholic beverages and tobacco. Duty on sweets and ice cream was abolished as of 2017.
 Stamp Duty 
Stamp duty is not imposed in Finland.
 Value Added Tax (VAT)/Goods and Services Tax (GST) 
For VAT/GST and similar taxes, see the VAT Navigator.

10. Special Industries 

10.1. Oil, Gas and Mineral Extraction 
With effect from January 1, 2024, the Mining Minerals Tax Act (314/2023) imposes a tax on mining activities. The tax is payable on specified minerals mined in Finland, excluding minerals found as a result of gold panning. The tax payable on metal ores is 0.6 percent of the taxable value of their metal content. The tax on non-metallic minerals is 0.2 euros per tonne of mined ore or industrial mineral. 
The Finnish tax authority will set the taxable values for metals each year, based on international market prices and other factors.

10.2. Banking and Finance 
There are a few special provisions in the Finnish Business Income Tax Act that are applicable only to banks. The special provisions relate to the tax deductibility of certain expenses and credit loss reserves.
With effect from January 1, 2015, a temporary bank tax was eliminated and replaced by rules implementing the EU Bank Recovery and Resolution Directive (BRRD). The BRRD, which sets out common requirements for when and how authorities will intervene to support troubled banks, provides, among other things, that Finnish banks must make contributions to resolution funds that will be used to finance recovery plans for failing banks.
An agreement between Finland and the United States under the provisions of the U.S. FATCA rules regarding foreign financial accounts became effective March 2, 2015. In addition, the OECD Common Reporting Standard (CRS) entered into force on April 15, 2016. Finland has previously implemented similar automatic exchange of tax information frameworks in connection with FATCA and the Directive for Administrative Cooperation 2014/107/EU (DAC2). The tax authority has published further guidance on CRS and DAC2 reporting.
Otherwise, the general tax regime is applicable to banking and finance companies.

11. About the Authors 
Mikko Alakare and Anette Laitinen    
 Castrén & Snellman Attorneys Ltd, Helsinki 
 Last reviewed/updated: August 5, 2024