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


  • The act on the minimum tax rate for large-scale corporate groups (Laki suurten konsernien vähimmäisverosta 1308/2023) entered into force on 1 January 2024, and it is applied to accounting periods beginning on or after 31 December 2023.
  • The OECD has released a new commentary to the Model Rules: International tax reform: OECD/G20 Inclusive Framework on BEPS taking further steps on the implementation of the Two-Pillar Solution - OECD
  • The newly published Consolidated Commentary to the Global Anti-Base Erosion Model Rules incorporates all guidance released up until December 2023.
  • The Tax Administration is preparing multiple guidance documents on the minimum tax rate for large-scale groups. The guidance documents will be released as soon as they are completed in 2024.

  • An information return on top-up tax is based on an international standard. The data content is defined in OECD publication “Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (Pillar 2)”. The OECD is preparing a reporting schema, which is anticipated to be ready for release in autumn 2024.

  • A top-up tax return will be filed only when a Finnish constituent entity is liable to pay a top-up tax, in Finland. The Tax Administration is preparing the data content of the return.

  • If you have any questions, please send email to: Minimivero(a)

General information about Pillar Two

Starting from tax year 2024, large-scale corporate groups’ excess profit is subject to a minimum tax rate of 15%, regardless of the constituent entities’ country of location. The effective tax level is considered country by country. If the effective tax rate in a country where a constituent entity is located is less than 15%, the minimum tax rate is achieved by imposing an additional amount of tax, i.e. a top-up tax. The top-up tax is imposed as a Qualified Domestic Minimum Top-up Tax (QDMTT) of a low-taxed country, or it is imposed based on the Income Inclusion rule (IIR) of the parent entity’s country or the Undertaxed Profits rule (UTPR) of countries where other constituent entities are located. 


  • All the information needed for calculating the group's top-up tax is filed in an information return on top-up tax.
  • Information on a foreign filer is filed in a notification regarding the filer of the information return on top-up tax.
  • Information needed for the collection of a top-up tax or domestic top-up tax in Finland is filed in a top-up tax return.
  • The returns for tax year 2024 must be filed by 30 June 2026.

Detailed guidance

The Tax Administration’s detailed guidance will be published in 2024.

Topics discussed in the guidance documents:

  • Minimum tax rate system applied to large-scale groups (overall view)
  • Group identification, and allocation of profit to constituent entities
  • Calculation of the qualifying income or loss
  • Calculation of adjusted covered taxes
  • Calculation of effective tax rate and top-up tax
  • Tax rule application, and allocation of top-up tax
  • Special circumstances regarding permanent establishments
  • Safe harbour rules
  • Filing and tax assessment procedure in Finland
Page last updated 6/18/2024