The Netherlands and Finland have both introduced draft laws to update their global minimum tax rules, following the OECD’s Pillar Two guidelines. The changes set a 15% minimum tax rate for multinational and local companies with a turnover of at least €750 million.
The draft legislation in the Netherlands, presented as part of its 2025 budget proposal, updates the Minimum Tax Act 2024. Key changes include a “tie-breaker rule” for calculating top-up taxes based on local accounting standards, and hybrid mismatch rules to prevent misuse of tax benefits. Most changes will apply retroactively from December 31, 2023, with hybrid mismatch rules starting from December 31, 2024.
Finland’s draft law clarifies terms like “fiscal year” and “ultimate parent entity” and incorporates OECD hybrid mismatch rules. It also updates rules on tax credits and income deductions.
To access the Draft Proposal of the Netherland, click here.
To access the Draft Proposal of the Finland, click here.