Minimum tax rate for large-scale groups (OECD Pillar Two)
CURRENT INFORMATION
- The Goverment proposes an amendment to enforce the latest amendment to the Directive on Administrative Cooperation. The amendment would simplify the reporting of information regarding the minimum tax rate for large-scale multinational groups. Read more on the website of the Finnish Government (available in Finnish and Swedish, link to Finnish).
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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.
- 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
Attention begins.
Detailed guidance
The Tax Administration’s detailed guidance documents will be published as soon as they are completed.
Topics discussed in the guidance documents:
Minimum tax rate for large-scale groups (in Finnish and Swedish only)
Calculation of adjusted covered taxes (in Finnish and Swedish only)
Group identification, and allocation of profit to constituent entities
Calculation of the qualifying income or loss
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
Attention ends