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Finland Amendments to CFC Rules to Comply with EU Anti-Tax Avoidance Directive Submitted to Parliament

06 November 2018

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Proposed Changes

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Finland

On 1 November 2018, draft legislation (HE 218/2018) for the amendment of Finland's controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD) was submitted in parliament. Changes include: An expansion of the CFC rules to cover persons subject to limited tax liability in Finland if the holding in a foreign CFC relates to a permanent establishment in Finland; The amendment of the definition of CFCs to provide that a foreign entity or permanent establishment will be considered a CFC if a Finnish taxpayer holds itself, or together with related parties, a direct or indirect participation...