Mining 2025

FINLAND Law and Practice Contributed by: Tarja Pirinen, Fiiu Linninen, Teija Lius and Marko Koski, HPP Attorneys Ltd

4.2 Tax Incentives for Mining Investors and Projects Electricity tax for class I electricity is 2,253 cent/ KWH. The lower electricity tax rate of 0,063 cent/ KWH is for electricity used for industry, such as mining and enrichment (class II). Tax incentives for energy-intensive industry, such as mining and enrichment, will be abol - ished starting from 1 January 2025. There are no tax stabilisation agreements avail - able in Finland. 4.3 Transfer Tax and Capital Gains on the Sale of Mining Projects The sale of goods is generally subject to 25,5% VAT, but if assets belonging to a business are transferred in connection with the sale of the business, the sale of assets is exempted from VAT, provided that the purchaser continues to use the assets in the business. Transfer of real estate located in Finland is sub - ject to transfer tax of 3% of the sales price. The transfer of shares in Finnish companies is sub - ject to a transfer tax of 1.5% if one of the parties to the transaction is a Finnish resident. Capital gains from the disposal of business assets are taxed as normal income with a tax rate of 20%. Among other requirements, if the seller has owned at least 10% of the fixed-asset shares in the company for at least one year, the sale of shares may be treated as tax-exempted. Non-Finnish-resident entities are subject to capi - tal gains tax on the transfer of real estate located in Finland. Transfer of shares or similar rights is subject to capital gains tax if more than 50% of the total assets consists directly or indirectly of Finnish real estate. Some of the Finnish tax

treaties may, however, prevent taxation of capital gains on indirectly owned Finnish real estate.

5. Mining Investment and Finance 5.1 Attracting Investment for Mining Finland’s good infrastructure, the large, sparsely populated areas and the availability of detailed and extensive geological data produced by the Geological Survey of Finland make it an attrac - tive mining country. Furthermore, Finland’s sta - ble political and economic situation are positive factors. In addition, Finland has leading knowl - edge and suppliers in the area of mining tech - nology. Finland has geological potential for minerals required for green transition – eg, cobalt, cop - per, lithium, nickel and graphite. 5.2 Foreign Investment Restrictions and Approvals in the Exploration and Mining Sectors There are no special rules on foreign investment approval or restriction on foreign direct invest - ment in the exploration and mining sectors. The Finnish Act on the Screening of Foreign Corpo - rate Acquisitions (No 172/2012, laki ulkomaal- aisten yritysostojen seurannasta ) applies where at least 10%, one-third or 50% of voting rights in a Finnish target are acquired by a foreign inves - tor – ie, a natural or legal person not domiciled/ registered in Finland or in the EU or one of the EFTA member states, depending on the sector in which the Finnish corporate target operates. For acquisitions in the defence and security industry, a mandatory, pre-closing approval must be sought from the Ministry of Economic Affairs and Employment of Finland. With respect to a Finnish target that, based on its industry,

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