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Finland Consulting on Draft Laws for Implementation of ATAD Exit Tax and Hybrid Mismatch Provisions

18 June 2019

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Proposed Changes

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Finland

Finland's Ministry of Finance has launched public consultations on the implementation of the exit tax and hybrid mismatch provisions contained in the EU Anti-Tax Avoidance Directive (ATAD). Exit Tax Proposal The exit tax proposal provides for the inclusion of provisions on exit taxation in the Law on Business Taxation, including that the unrealized value of assets would be considered taxable income when a taxpayers transfer funds from a permanent establishment in Finland to the head office or a permanent establishment in another State and the transfer would no longer confer taxing rights in Finland on such assets. The same would...