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

CURRENT INFORMATION

Constituent entities are required to use MyTax to submit their returns related to the minimum tax. Returns can be submitted in MyTax as of 30 January 2026. Read more: Topical information on the minimum tax for large-scale corporate groups
The parliament passed the legislative amendment to enforce the latest changes to the Directive on Administrative Cooperation. The amendment will simplify the reporting of information regarding the minimum tax rate for large-scale multinational groups. Read more on the Ministry of Finance’s web site (available in Finnish and Swedish, link to Finnish)
The government proposes changes to the act on the minimum tax rate for large-scale groups
The proposed changes would bring domestic regulation into line with international guidelines drafted in 2024 and 2025. In addition, the Tax Administration could issue advance rulings regarding the minimum tax. Companies could request advance rulings for accounting periods that have started on or after 1 January 2024. A new provision on tax evasion would be added to the act to prevent arrangements seeking to evade the minimum tax. The provision would be applied to accounting periods starting on or after 1 January 2027.
- Government proposal HE 196/2025 vp (available in Finnish)
- Changes to minimum tax rate for large-scale groups (vm.fi) (available in Finnish and Swedish, link to Finnish)
OECD has released a new version of the international standard regarding the content of the information return on top-up tax, GloBE Information Return (January 2025), and an XML schema that will be used in the reporting of information and in the exchange of information between authorities.
- Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January 2025) | OECD
- GloBE Information Return (Pillar Two) XML Schema | OECD
Updated commentary 2025: Consolidated Commentary to the Global Anti-Base Erosion Model Rules
- The commentary includes a central record of legislation with transitional qualified status for purposes of the Global Minimum Tax. The record also includes information on whether the domestic top-up tax of a jurisdiction meets the conditions of the safe harbour rule on the dometic top-up tax. The Finnish income inclusion rule and domestic top-up tax have been considered to meet the criteria, also as regards the safe harbour rule on dometic top-up tax.
If you have any questions, please send email to: Minimivero(a)vero.fi

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.

Filing

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.