How to file the required information

All constituent entities located in Finland need to submit a GloBE information return, to provide information on their top-up tax. Submittal of the GIR can be centralised to a single consolidated entity. If so, responsibility for submittal will fall on the group’s ultimate parent entity, or alternatively, on a designated entity other than the ultimate parent.

The centralised submittal of the GIR requires that the ultimate parent entity or the designated filing entity is located in a jurisdiction having a Tax Information Exchange Agreement (TIEA) with Finland, in effect for the reportable fiscal year.

In the EU, the exchange of tax information is based on the DAC9 Directive (EU) 2025/872. As a result, there is no need for an additional TIEA. A Finnish constituent entity is exempted from submitting the GIR if the group files its GIR centrally in another EU Member State.

In the case of non-EU jurisdictions, centralised GIR submittal requires Finland to have a TIEA with the country where the filer entity is located. This requirement is considered satisfied when the jurisdiction and Finland have signed and activated the GIR MCAA, the specific agreement on information exchange. For a list of agreements currently in effect, visit the website of the OECD: Central Record for purposes of the Global Minimum Tax | OECD.

In order for the Finnish constituent entity to become exempted from GIR reporting, the jurisdiction and Finland need to have their TIEA in effect by the due date of the GIR relating to the fiscal year being reported. From this, it follows that Finnish constituent entities should ensure that there is an agreement on information exchange, in effect before the due date, between the reporting entity’s jurisdiction and Finland. If the agreement is not in effect, the GIR must be submitted in Finland.

A further requirement for the exemption from the obligation to report information is that the entity filing the GIR has actually filed it in its country of location within the deadline, and in compliance with the requirements on content.

If an MNE group implements the centralised GIR and an entity outside Finland files it, the Tax Administration will receive the information it needs through the exchange of tax information between Finland and the jurisdiction concerned.  As the GIR is filed in another jurisdiction, the Finnish constituent entities must submit a notification informing the Tax Administration of the filing entity's identity and location (a Notification of filing constituent entity).

The GloBE information return must contain the information needed to identify constituent entities, information on the group structure, and the information necessary for calculating the actual tax rate and any top-up tax in jurisdictions where the constituent entities are located. In addition, the group’s selection for the reportable year and the group’s five-year selections must be indicated.

The content requirements are based on the international standard – for more information, see the OECD website: Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January 2025): Inclusive Framework on BEPS.

The GIR must always provide the group’s basic details. Write the basic details into the General Section. The following are considered ‘basic’ details:

• details serving the purpose of identifying the corporate group, the ultimate parent entity, all constituent entities and members of any joint-venture group,
• details on the structure of the group,
• financial statements of the ultimate parent entity and information regarding the accounting standards to be applied when consolidated financial statements are prepared, and
• details on how minimum tax rules are applied in jurisdictions where the group’s constituent entities are located.

Included in the GIR is a summary table that provides a high-level overview in respect of every jurisdiction. The Summary is for the following information: 

• To identify jurisdictions, which may collect the top-up tax that may be generated there
• Whether a safe harbour or exemption was applied in a jurisdiction
• Whether substance-based income exclusions may affect top-up taxes
• Details on the effective tax rate (ETR) and the top-up tax in the jurisdiction

The information needed to calculate the ETR and top-up tax is reported in the Jurisdiction Section. This information should cover all jurisdictions where the group’s constituent entities are located. However, there is no need to provide details on a jurisdiction for which no country can collect the top-up tax that may be generated.

In the event that there is a joint-venture operation, the related information must be submitted separately from the other entities located in the same jurisdiction. The information for a group formed as a joint venture must be reported as if the parent entity of that group would be the ultimate parent entity of another group, distinct from the MNE group subject to GIR reporting.

The Jurisdiction Section should provide details on an applied safe harbour in the jurisdiction, or details on an applied exception. If one of the safe harbours or exceptions is applied, there is no need to provide any information for the jurisdiction other than what is required under the relevant safe harbour or exception rules.

Otherwise, you must report the information needed for calculating the ETR, which means information on the book-profit adjustments made for arriving at the qualified profit or loss and at the adjusted covered tax. In the event that the ETR in a jurisdiction remains below the minimum rate, you must additionally give the details needed for computing the top-up tax.

The selections set out in the Act on the minimum tax (Laki suurten konsernien vähimmäisverosta (1308/2023)) are choices, which the filing constituent entity must indicate when submitting the GIR. The Jurisdiction Section is for providing information on the selections made. In other words, no selections can be made or changed after the GIR has been filed.

In principle, the calculations reported on the GIR must be submitted separately for each distinct entity belonging to the group. However, for fiscal years beginning no later than 31 December 2028 and ending no later than on 30 June 2030, it is possible, subject to certain conditions, to apply a “simplified calculations” approach. This means that the calculations reported on the GIR can concern an entire jurisdiction.

Simplified calculations will be applicable in a jurisdiction where no top-up tax is generated, or where no need arises to allocate a top-up tax to constituent entities, for reasons including the circumstance that the group’s parent entity, that applies the Income Inclusion Rule, is the sole owner of all the constituent entities located in jurisdiction. If, under the minimum tax rules, a top-up tax needs to be allocated to the constituent entities, no simplified calculations can be applied.

Simplified calculations are not mandatory during the transition period. In other words, the group can submit multiple calculations, which are specific for every constituent entity in all relevant jurisdictions.

If the group’s ultimate parent entity or a designated entity files the GIR in its jurisdiction, the authorities in the jurisdictions of other constituent entities will receive the necessary information through automatic exchange of tax information.

The GIR information made available to fiscal authorities will be exchanged between them in accordance with the dissemination approach, defined by the OECD Standard and by the DAC9 Directive.  Accordingly, the dissemination of information will depend on the existence of taxing rights in the different jurisdictions with regard to any top-up tax that might be generated.

When the minimum tax rules are applied, the top-up tax is collected under the Income Inclusion Rule in the jurisdiction of the parent entity’s location, the domestic top-up tax (QDMTT) is collected in the jurisdiction of the constituent entity located in a low tax regime, and in compliance with the Under-taxed profits rule (UTPR), the top-up tax is collected in the jurisdictions of the other constituent entities’ location providing that the UTPR is in force in those jurisdictions.

The information-dissemination method will determine which information derived from GIR reporting can be accessed by information exchange by different jurisdictions when applying the minimum tax rules as referred to above.

• The jurisdiction where the ultimate parent entity is located can receive all the information derived from GIR reports, if it is the jurisdiction that applies minimum taxation.
• The jurisdiction of the ultimate parent entity’s location – applying minimum taxation – receives the basic details of the group, the Summary providing information on every jurisdiction, and the Summary details on the jurisdictions where it could collect the top-up tax that might be generated.
• The jurisdiction where the constituent entity is located, which only applies the qualifying domestic top-up tax (QDMTT), can receive the group’s basic details and the details of its own jurisdiction.

The fiscal authorities will conduct the automatic exchange of information using the details given by the MNE group in its GIR reporting. From this, it follows that the group must apply this method of dissemination of information when declaring which jurisdictions should receive the information in the different sections of the GIR.
 

The table below illustrates the applicable dissemination of information.

In accordance with Chapter 9, section 2 of the Act on the minimum tax, the domestic top-up tax to be paid by a large Finnish group and the top-up tax based on the income inclusion rule are reduced to zero in the first five years when the provisions of the Act on the minimum tax concern the large Finnish group for the first time. This also requires, with regard to Finnish domestic top-up taxes, that the constituent entity has no owner located in another jurisdiction that would be liable for applying the income inclusion rule in the owner’s jurisdiction.

In general, when the transition rule applies to large Finnish groups, there is no need to provide information on the GIR other than basic details on the group (the General Section) and the Summary, by every relevant jurisdiction.

The deadline for submitting the GloBE information return (GIR) is 15 months from the end date of the fiscal year. However, for the first submittal, the deadline is extended to 18 months from the end date of the fiscal year.

You need to submit the GIR on an .xml file in MyTax, in compliance with the direction and guidance on the OECD-released GloBE Information Return (Pillar Two) Status Message Schema. The technical guidance has a number of descriptions of the fields to be filled in, information on the check processes programmed into the system, and instructions for making corrections.

It is the responsibility of the Finnish constituent entity to submit the notification. It is possible to centralise the notification to one Finnish constituent entity (which will then be called the ‘designated local entity).

Because the notification concerning the group’s Finnish entities must come from a Finnish entity, a constituent entity outside Finland is cannot submit it.

The notification should indicate the name of the filing constituent entity being in charge of submitting the GIR, including full identification information and the name of the country/jurisdiction. 

In addition, if there is a designated local unit here, filing the notification on behalf of all Finnish units, the notification should give full details on the Finnish entities.

If during the fiscal year, a constituent entity had been part of two or more different corporate groups, it must file a notification providing information valid on the end date of the fiscal year. The notification’s “additional information” space should in that case be filled in, to name the other groups to which that constituent entity had belonged previously during the fiscal year.

The deadline for submitting the notification is 15 months from the end date of the fiscal year. However, for the first submittal, the deadline is extended to 18 months from the end date of the fiscal year.

You need to submit the notification electronically, in MyTax.

The constituent entity located in Finland must file a top-up tax return for the year, for which the entity needs to pay top-up tax to Finland. No centralised submission of the top-up tax return is possible.

If the constituent entity does not have to pay a top-up tax to Finland for the fiscal year being reported, it does not have to file a top-up tax return unless the Tax Administration requests it for reasons related to tax control.

The constituent entity is required to provide information, which the Tax Administration will need for determining the top-up tax and for assessing the taxes for the year. The required information is the following:

Identification of the constituent entity filing the return

• The constituent entity’s name
• Business ID
• Other information to facilitate identification

Calculating the top-up taxes specifically per jurisdictions

You need to submit a calculation of top-up taxes for the relevant jurisdictions, from where a top-up tax payable to Finland is allocated to the constituent entity. Almost all the information to show on the calculation is included in the information of the GloBE information return (GIR).

If the constituent entity was sold to a new owner during the fiscal year, and the year’s top-up tax is connected to 2 different periods of ownership by 2 groups in one jurisdiction, you should show both groups that had owned the constituent entity during the year. This means that you need to provide two distinct calculations for one jurisdiction.

Additional information related to the domestic top-up tax

The constituent entity needs to provide details on any investment entities, to which domestic top-up tax is allocated in Finland.

The following information on investment entities is required:

• The amount of domestic top-up tax allocated to the investment entity
• The investment entity’s name
• Business ID
• Identification by name(s) and by Business ID(s) of constituent entities located in Finland that own shares – with the percentages of ownership shown – in the reported investment entity
• The constituent entity’s own portion of the top-up tax allocated to the investment entity in euros

This section is also for reporting the monetary amounts of tax subtracted from the adjusted covered tax, such as tax on the profits of a controlled foreign company, tax on the profits of a hybrid entity, and tax on the profits of a permanent establishment.

Additional information

The top-up tax return has an “additional information” field designed for adding free-form text to provide various kinds of additional information.

Please note that you should always write into the “additional information” field how the domestic top-up tax is allocated.

You can also write a description into the “additional information” field also if top-up tax had been generated for the constituent entity – payable to Finland for the fiscal year – and connected to 2 different periods of ownership (or more) by 2 groups (or more), which had been the constituent entity’s owners that fiscal year. A constituent entity may, due to corporate acquisitions and sales, be part of two or more different groups within one fiscal year.

The deadline for submitting the top-up tax return is 15 months from the end date of the fiscal year. However, for the first submittal, the deadline is extended to 18 months from the end date of the fiscal year.

Complete the electronic fillable form in MyTax to file the return.

The accounting period of the group is calendar year. The group’s annual revenue according to the consolidated financial statements: 

The annual revenue was at least €750 million in 2023 and 2025, so the act on the minimum tax rate for large-scale groups is applied to the group from accounting period 2026 onwards. The first information returns must be filed within 18 months from the end of the accounting period, i.e. by 30 June 2028. The information returns for the next accounting period must be filed within 15 months from the end of the accounting period, i.e. by 31 March 2029. 

According to chapter 10, § 1 of the act on the minimum tax rate for large-scale corporate groups, the act entered into force on 1 January 2024 and is applied for the first time to accounting periods beginning on or after 31 December 2023. If the accounting periods of the example are 12 months, the accounting period that ended on 31 March 2024 had begun before the act started to be applied, so the act is applied for the first time to the accounting period that ended on 31 March 2025. When the information return is filed for the first time, the time limit is 18 months, so the first GloBE information return must be filed by 30 September 2026.

For purposes of minimum taxation, the permanent establishment is a constituent entity, which has an independent reporting obligation. If the foreign company or main operation files the GloBE information return (GIR) in its country of location, then the Finnish permanent establishment must file the notification of the filing constituent entity in MyTax.

If the GIR is filed in Finland, then no notification needs to be filed here. If the actual tax rate in Finland is less than 15%, then the top-up tax is taxed in Finland as domestic top-up tax. In that case, a top-up tax return must also be filed.

The group has entities in jurisdictions A, B, C and D.

• The Income Inclusion Rule (IIR) is not in force in the jurisdiction of the ultimate parent entity A1.
• B1 and B2 are located in Finland, the IIR and the Qualified Domestic Minimum Top-up Tax (QDMTT) are in force.
• B1 and B2 are required to submit reports to Finland.

The group can designate an entity to file the GloBE information return for the entire group. Information on all group entities must be given in the general section. Jurisdiction-specific information must be filed on jurisdictions B and C because B1 and B2 are not obliged to apply the IIR in the case of low taxation in C, nor the QDMTT in the case of low taxation in B. If the Undertaxed Profits Rule (UTPR) were in force in Finland, information should also be filed on jurisdictions A and D. This would also be the case if the QDMTT were in force in jurisdictions A and D.

• Group’s ultimate parent entity A1 is located in jurisdiction A.
• Subsidiary entities B1 and B2 are located in Finland.
• The group’s GloBE information return is filed by A1.

In Finland, a notification must be filed in MyTax to specify the entity filing the GloBE information return and to submit identifying details (Business ID) on the Finnish entities. Only one notification is needed if it contains the information on both B1 and B2.

Because the domestic top-up tax complying with the QDMTT safe harbour requirements is in force in Finland, the domestic top-up tax calculations are reported in the section specific to the Finnish jurisdiction on the GloBE information return. No calculations are needed if the prerequisites for applying the safe harbour rule regarding the transition period of country-by-country reporting are met in Finland.

The group has entities in jurisdictions A, B and C.

• The ultimate parent entity is Finnish: the GloBE information return is filed in Finland, notifications are filed in other relevant countries.
• Information on all constituent entities is included in the general information.
• Jurisdiction-specific information is submitted on all the three jurisdictions.
• The information content regarding a jurisdiction depends on whether a safe harbour rule or an exemption is applicable.
  
  • In jurisdiction B, a safe harbour rule is applicable, so information relevant to the rule is filed.
  • In jurisdiction C, no safe harbour rule is applicable, so information needed to determine the actual tax rate and any top-up tax is filed.
• The Finnish constituent entity files a top-up tax return if it is required to pay top-up tax in Finland.