FINLAND Trends and Developments Contributed by: Petteri Rapo, Markku Renko, Henri Becker and Jaakko Niskala, Svalner Atlas Finland
and restructuring decisions where interest limitation and loss usage interact. Private capital and fund policy: easing market friction Finland’s policy agenda also highlights reforms aimed at improving the venture capital and private equity environment. The mid‑term package references work to facilitate foreign investment into Finnish funds, to assess new fund structures, and to implement EU‑enabled fund structures such as ELTIFs, alongside other procedural simplifications. These measures are relevant because Finland’s capi - tal market relies heavily on predictable tax and work - able procedure for cross‑border investors. For clients, the trend is towards a more “investor‑usable” frame - work, though outcomes will depend on the final form of legislative changes. 2. Transaction and Restructuring Policy: Making Tax Neutrality More Usable Share‑for‑share transactions and rollovers A key practical issue raised with current rules is that they can be restrictive where cash is involved, and there is a stated intention to review these constraints to facilitate tax‑neutral rollovers in real‑world transac - tions. In practice, rollover mechanics are a common source of friction in Nordic and cross‑border deals, particu - larly where management investors and anchor share - holders are involved. Changes in this area can materi - ally affect how deals are structured and executed in Finland. Broader M&A simplification agenda The same government policy package also signals a wider review of M&A tax treatment to correct dis - tortions and simplify processes. While the precise legislative outcome remains to be seen, the direction suggests a preference for rules that support deal exe - cution while protecting the tax base through targeted safeguards rather than broad complexity. For clients, the practical implication is that Finnish deal structuring may become more flexible in certain areas, but also more “rule‑driven” in terms of docu -
mentation and process. This combination is typical of reforms intended to support investment while main - taining a predictable tax framework. 3. Indirect Tax Policy: the 13.5% Reduced VAT Rate is Now Live What changed on 1 January 2026 Finland has lowered its reduced VAT rate from 14% to 13.5% from 1 January 2026 for a broad set of goods and services. The Tax Administration lists the cat - egories covered, including groceries and food, res - taurant and catering services, passenger transport, accommodation services, pharmaceuticals, books (printed and electronic), and certain admissions and sports‑related services, and it notes that public broad - casting moved to 13.5% from the previously applied 10%. This is a meaningful change for consumer‑facing sec - tors, but it also affects any business with mixed sup - plies or complex pricing models. For cross‑border groups, it is a reminder that Finnish VAT policy con - tinues to evolve and that invoicing systems must be kept aligned with changes. Practical transition rules matter Businesses typically need to adjust invoicing rules, contract language and customer communications, particularly where delivery spans year‑end or where long‑term services are billed in advance. 4. Transparency Policy: DAC8/CARF Crypto Reporting Becomes Real in 2026 Why crypto reporting is a policy priority The government in Finland has made clear that cryp - to‑asset reporting is expanding due to international commitments. The Tax Administration states that, starting in tax year 2026, it will receive more exten - sive information on trading in crypto-assets, and that international exchange of information will intensify. It also links this to the OECD’s Crypto‑Asset Reporting Framework (CARF) and the EU’s DAC8 directive. This is not only a “crypto” issue. It is part of a broader transparency trend, where cross‑border data flows allow tax authorities to match taxpayer disclosures against third‑party information more effectively. For
143 CHAMBERS.COM
Powered by FlippingBook