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Did you submit a return late, or was it inaccurate or incomplete? – minimum tax rate for large-scale groups
A GloBE information return (GIR), a notification of the filing constituent entity and a top-up tax return must be filed within 15 months from the end of the accounting period.
However, in the first accounting period during which the group falls within the scope of the act on the minimum tax rate for large-scale groups in Finland, the filing deadline is 18 months from the end of the accounting period. A return is deemed to have been submitted when it is received by the Tax Administration.
If you file any of the above returns and notifications or any information included in them late, the Tax Administration may impose a late-filing penalty or a punitive tax increase on you.
The Tax Administration can also impose a late-filing penalty or a punitive tax increase on account of any other filing inaccuracies or omissions.
Late-filing penalty
The Tax Administration can impose a late-filing penalty on a constituent entity for late filing of a return or notification submitted based on the act on the minimum tax rate for large-scale groups. There are differences in late-filing penalties imposed. Below you will find information about the late-filing penalty imposed on different returns and notifications.
The Tax Administration can impose a late-filing penalty on a constituent entity if
- the constituent entity submits a GIR after the deadline but before the tax assessment is completed, or if
- the constituent entity corrects an omission or error in the GIR at its own initiative before the tax assessment ends.
The late-filing penalty is €5,000.
For a special reason, the Tax Administration can give the constituent entity an opportunity to provide further information before the late-filing penalty is imposed.
The Tax Administration issues a separate decision on the late-filing penalty.
The Tax Administration can impose a late-filing penalty on a constituent entity if the constituent entity submits a notification of the filing constituent entity after the deadline.
The constituent entity must file a notification of the filing constituent entity in MyTax within 18 months from the end of the accounting period. However, when a group falls within the scope of the act on the minimum tax rate for large-scale groups for the first time, the notification can be submitted within 24 months from the end of the accounting period.
The late-filing penalty is €1,000.
For a special reason, the Tax Administration can give the constituent entity an opportunity to provide further information before the late-filing penalty is imposed.
The Tax Administration issues a separate decision on the late-filing penalty.
The Tax Administration can impose a late-filing penalty on a constituent entity if
- the constituent entity submits a top-up tax return at its own iniative after the deadline but before the tax assessment ends, or if
- the constituent entity corrects an omission or error in the top-up tax return at its own initiative before the tax assessment ends.
The late-filing penalty is €1,000.
For a special reason, the Tax Administration can give the constituent entity an opportunity to provide further information before the late-filing penalty is imposed.
You will find the late-filing penalty in the tax decision.
Punitive tax increase
The Tax Administration can impose a punitive tax increase on a constituent entity based on a return or notification filed under the act on the minimum tax rate for large-scale groups. There are differences in the amounts of punitive tax increase imposed. Below you will find information about the late filing penalties imposed on different returns and notifications.
The Tax Administration can impose a punitive tax increase on a constituent entity that is liable to submit returns in Finland if
- the constituent entity does not submit a GIR until after the end of the tax assessment
- the constituent entity has submitted a GIR or any other related information, document or account required by law as inaccurate or incomplete and has not corrected the omission or error at its own initiative before the end of the tax assessment
- the constituent entity has neglected its obligation to file a GIR.
The Tax Administration always sends a hearing letter about the punitive tax increase to the constituent entity before making a final decision on the matter.
The Tax Administration will issue a separate decision on the punitive tax increase.
The Tax Administration can impose a punitive tax increase on a constituent entity that is liable to submit notifications in Finland if
the constituent entity has not filed a notification of the filing constituent entity before the tax assessment is completed.
The Tax Administration always sends a hearing letter about the punitive tax increase to the constituent entity before making a final decision on the matter.
The Tax Administration will issue a separate decision on the punitive tax increase.
The Tax Administration can impose a punitive tax increase on a constituent entity if
- the constituent entity does not submit a top-up tax return until after being requested to do so or after the tax assessment has been completed
- the constituent entity has submitted a top-up tax return or any related information, document or account required by law as inaccurate or incomplete
- the constituent entity has neglected its obligation to file a top-up tax return.
The Tax Administration always sends a hearing letter about the punitive tax increase to the constituent entity before making a final decision on the matter.
You can find the punitive tax increase on the tax decision.
Amount of punitive tax increase
The amount of punitive tax increase is usually determined on the basis of the increased top-up tax.
The amount of punitive tax increase is laid down in chapter 8, § 16 of the act on the minimum tax rate for large-scale groups. The following table shows how the punitive tax increase is determined in the case of the GloBE information return or top-up tax return:
| Type of negligence Chapter 8, § 15 |
Amount of punitive tax increase Chapter 8, § 16 |
Punitive tax increase % |
Basis of punitive tax increase |
|---|---|---|---|
|
The return is incomplete or incorrect or no return has been filed at all. Subsection 1, paragraphs 1 and 2 |
subsection 1, paragraph 1 | at least 15%, no more than 50% |
repeated negligence or the constituent entity’s actions show apparent disregard for tax obligations |
|
No return has been filed. Subsection 1, paragraphs 1 and 2 |
subsection 1, paragraph 2 | 25% of the increased amount of tax | taxation by estimation |
|
The return is incomplete or incorrect or no return has been filed at all. Subsection 1, paragraphs 1 and 2 |
subsection 1, paragraph 3 |
5% |
open to interpretation or unclear or a situation where a punitive tax increase under paragraph 1 or 2 of § 16 is unreasonable for a special reason |
|
The return is incomplete or inaccurate. Subsection 1, paragraphs 1 and 2 |
subsection 1, paragraph 4 | 2% | the constituent entity claims adjustment of an error at its own initiative after the tax assessment has been completed and it has fulfilled its obligation to provide additional information |
|
The return is incomplete or incorrect or no return has been filed at all. Subsection 1, paragraphs 1 and 2 |
subsection 1, paragraph 5 | 10% | other situations than those specified in paragraphs 1 to 4 |
The punitive tax increase is at least €10,000 if the neglect has affected the amount of top-up tax. In these cases, the tax increase has no upper limit in euros. The Tax Administration calculates the punitive tax increase in accordance with the table above.
However, unless the amount of top-up tax imposed is too low because of an error in the top-up tax return, the amount of punitive tax increase is at least €5,000 and at most €25,000.
When the punitive tax increase is imposed based on a notification of the filing constituent entity, it is at most €25,000.
When is it possible not to impose a late-filing penalty or punitive tax increase?
The Tax Administration does not impose a late-filing penalty
- when a return is filed late for a reason beyond the constituent entity’s control
- in the case of minor negligence
- when there is an acceptable reason or other special reason for the negligence.
Further, the Tax Administration does not impose a late-filing penalty on a GloBE information return or a top-up tax return if the constituent entity has failed to report information that would be to its benefit, unless the omission is recurring or the constituent entity’s actions show an apparent disregard for their tax obligations.
The Tax Administration does not impose a punitive tax increase
- when the constituent entity has failed to report information that would be to its benefit, unless the omission is recurring or the constituent entity’s actions show an apparent disregard for their tax obligations
- in the case of minor negligence
- when there is an acceptable reason for the omission
- when imposing a punitive tax increase is unreasonable under the circumstances in an unclear or ambiguous situation under chapter 8, § 16, subsection 1, paragraph 3 of the act on the minimum tax rate for large-scale groups
- when imposing a punitive tax increase is unreasonable for another special reason.
Further, the Tax Administration does not impose a punitive tax increase on a top-up tax return when a punitive tax increase has been imposed on the constituent entity based on the act on the minimum tax rate for large-scale groups on account of the same error contained in a GloBE information return.
Transitional special provision on a punitive tax increase
The Tax Administration does not impose a punitive tax increase during a transitional period when the constituent entity has made efforts to learn about the content of the rules and has adhered to them in good faith.
The transitional period includes accounting periods starting before 31 December 2026 and ending no later than on 30 June 2028.