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

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 establishme…