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Finland Publishes Law Providing ATAD-Compliant Interest Restriction Rules

02 January 2019

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Approved Changes

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Finland

On 27 December 2018, Finland published Law 1237/2018 in the Official Gazette, which provides new interest deduction restriction rules that are compliant with the EU Anti-Tax Avoidance Directive. Key points of the rules are as follows: The general 25% of EBITDA interest deduction restriction for net interest expense is extended to both related and unrelated party debt; The EUR 500,000 safe harbor for related party debt is maintained and a separate EUR 3 million safe harbor is introduced for unrelated party debt; With respect to unrelated party debt, an exemption from the deduction restriction is provided for loans taken prior...