FINLAND Law and Practice Contributed by: Petteri Rapo, Markku Renko, Henri Becker and Jaakko Niskala, Svalner Atlas Finland
4. OECD/G20 Global Tax Reform 4.1 Pillar One – Amount B As of April 2026, Finland has not formally implement - ed Amount B, nor has it announced binding admin - istrative guidance or legislation adopting the OECD Amount B simplified and streamlined approach. Fin - land remains aligned with the OECD Transfer Pric - ing Guidelines generally, but Amount B is optional by design, and there is no public statement from the Finnish Ministry of Finance or the Finnish Tax Adminis - tration confirming adoption, planned adoption or local deviations. In the absence of a Finland-specific Amount B imple - mentation, distributors and baseline marketing/distri - bution activities remain subject to Finland’s ordinary transfer pricing framework, including the requirement to prepare transfer pricing documentation under the Finnish rules (documentation rules are unchanged even after the 2022 update to the transfer pricing adjustment provision). As a result, any simplification for baseline distribution would, in practice, need to be reflected through explicit domestic guidance or accepted administrative practice to have operational effect. 4.2 Pillar One – Amount A Finland supports Pillar One Amount A at the OECD/ Inclusive Framework level but has not yet implement - ed it domestically. Finland considers the practical impact on Finnish enterprises to be limited, supports implementation only via the Multilateral Convention (MLC), and has taken no unilateral action while the MLC remains unsigned and unratified. Finland has participated in OECD-level discussion on the taxation challenges of digitalisation and has supported the need for an international solution led through the OECD process, including the view that the digital economy should not and cannot be ring- fenced. This broader policy context aligns with Fin - land’s preference for multilateral implementation rath - er than unilateral domestic action in this area. The Finnish Tax Administration commentary further notes that implementing Amount A would require a multi - lateral convention that is not yet open to signature,
• Residents (permanent home in Finland or stay exceeding six months) are subject to unlimited tax liability and are taxed on their worldwide employ - ment income. • Non-residents (stay of six months or less) are taxed in Finland only on Finnish-source employment income. Individuals working in Finland for six months or less are generally treated as non-residents. Their employ - ment income may be taxed in Finland depending on the circumstances. • Default taxation: 35% final withholding tax on gross wages (after a standard deduction of EUR510 per month/EUR17 per day). • Optional progressive taxation: Non-residents from treaty countries may opt for progressive taxation instead of the flat 35%. Even for short stays, Finland may tax employment income if: • the employer has a permanent establishment (PE) in Finland; • the individual is a leased employee; • the individual is a performing artist or athlete; or • a tax treaty allocates taxing rights to Finland. Finland does not have separate domestic legislation specifically for “remote work PEs”. Instead, PE risk is assessed under the Finnish domestic law and tax trea - ties following OECD Model principles. Remote work performed physically in Finland is generally treated as Finnish-source employment income, regardless of employer location, unless a tax treaty restricts Fin - land’s taxing rights. Remote work performed outside Finland by a Finnish resident may qualify under the six-month rule, but only if the statutory conditions are met. 3.6 Other Income There are no other specific types of income subject to special taxation rules in Finland.
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