FINLAND Trends and Developments Contributed by: Petteri Rapo, Markku Renko, Henri Becker and Jaakko Niskala, Svalner Atlas Finland
Svalner Atlas Finland Eteläesplanadi 8 00130 Helsinki Tel: +358 10 219 3890 Email: finland@svalneratlas.com Web: www.svalneratlas.fi
Key Themes for 2026 Finland’s international tax environment in 2026 is being shaped by a cluster of policy moves rather than one single reform. The direction of travel is clear: improve competitiveness, simplify certain rules, and raise transparency where the tax base is perceived as vulnerable. Much of the agenda was signposted in the government’s 2025 mid‑term policy review and subsequent policy communications. A first theme is corporate tax competitiveness. The corporate income tax rate has been flagged for reduction to 18% from 2027, and the loss carryfor - ward period has been proposed to be extended to 25 years (starting from losses in the 2026 tax year). These changes, if implemented as proposed, affect modelling, deal structuring and the long‑term after‑tax return profile of investments in Finland. A second theme is targeted reform in transactions and investment markets. The same policy package high - lights potential updates to tax‑neutral reorganisations and share‑for‑share transactions, with a stated inten - tion to make rollovers more workable (including review of cash consideration limitations) and to support ven - ture capital and private equity investment structures. A third theme is indirect tax adjustments that affect consumer‑facing sectors and cross‑border supply chains. Finland’s reduced VAT rate has already been lowered from 14% to 13.5% from 1 January 2026 for a wide list of goods and services, and the Tax Adminis - tration has issued practical guidance on how to apply the rate change based on delivery/performance dates and advance payments.
A fourth theme is transparency and data‑driven enforcement. DAC8/CARF crypto‑asset reporting will expand the Tax Administration’s inbound information from 2026 onwards, with annual returns expected from service providers starting in 2027, and interna - tional exchange of information set to intensify. 1. Corporate Tax Policy: Rate Direction, Losses and the Investment Narrative Corporate income tax rate: the headline signal The most visible corporate tax policy signal remains the proposed reduction of Finland’s corporate income tax rate from 20% to 18% from 2027. It is positioned as a competitiveness and entrepreneurship measure. For clients, the immediate relevance is modelling and timing. Rate expectations can affect investment hurdle rates, deferred tax positions and the timing of income recognition where flexibility exists. This is particularly relevant for capital‑intensive projects and groups with large Finnish tax bases. Loss utilisation: a structural change if implemented A second significant policy item is the proposal to extend the loss carryforward period from ten years to 25 years starting from losses incurred in the 2026 tax year. This has been presented as part of the same competitiveness package and would, if implemented, change the “shape” of Finnish tax assets for cyclical and growth businesses. For clients, the impact is not only technical. Longer loss carryforward increases the value of Finnish plat - forms for long‑horizon investments, and it can change acquisition modelling where future profitability is expected to ramp over time. It also affects financing
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