Finland Tax Agency Posts Guidance on Pillar 2 Global Minimum Taxation, Safe Harbors, Transitional Provisions

The Finnish Tax Administration April 13 issued Guidance No. VH/7419/00.01.00/2025, on safe harbors and transitional provisions related to global minimum taxation of multinational enterprise (MNE) and large domestic groups under OECD Pillar Two. Topics covered include: 1) transitional relief reducing domestic supplementary taxes and undertaxed profits rule (UTPR) liability to zero for the first five financial years, subject to conditions; 2) transitional country-by-country (CbC) reporting safe harbor provisions, including de minimis, simplified effective tax rate (ETR), and substance-based tests; 3) provisions governing special situations, including groups not obliged to submit CbC tax reports, minority-owned group units, joint ventures, and investment ...