The minimum tax rate for large-scale groups: the first filing deadline is 30 June 2026

The purpose of the minimum tax-rate for large-scale groups is to ensure minimum-level taxation around the world. The minimum tax rate applies to multinational groups whose annual income according to the consolidated financial statements exceeds €750 million during at least two of the four accounting periods immediately preceding the accounting period in question. In the EU area, the minimum tax rate also applies to large domestic groups.

File all the required returns and notifications

There are three returns or notifications relating to the minimum tax rate for large-scale groups:

• A GloBE information return (GIR): all the information needed for calculating the group's top-up tax. The return is submitted as an XML file.
• A notification of the filing constituent entity: must be filed if the group files a GIR centrally in a country other than Finland.
• A top-up tax return: A constituent entity located in Finland submits the information needed for determining the top-up tax and for assessing the year’s taxes.

The groups must file the returns and notifications within 15 months from the end of the accounting period. However, the first filing period is 18 months. Returns for accounting periods that ended in 2024 must be filed by 30 June 2026. 

All the returns are submitted in MyTax.

More information on filing

Requesting an extension

If a group needs an extension for filing returns relating to minimum tax, an application must be submitted to the Tax Administration by 30 June 2026. The group can request an extension if it cannot file the returns within the time limits for a justified reason. The extension is requested in MyTax.

Advance rulings

Groups can request an advance ruling for accounting periods that have started on or after 1 January 2024. 

An advance ruling can be requested in the following matters: 

• The amount of top-up tax payable in Finland
• Calculation of the effective tax rate for a constituent entity or joint venture located in Finland
• The position of an entity, a permanent establishment or a foreign permanent establishment of a main entity located in Finland
• The location of an entity in Finland. 

The advance ruling must be requested before the deadline for filing the returns for the accounting period.

Read more about advance rulings

Any questions?

If you have any questions about the minimum tax rate for large-scale groups, please send email to: Minimivero(a)vero.fi.

Read more:

Minimum tax rate for large-scale groups (OECD Pillar Two)