Finland Implements New Rules on the Attribution of Profits to Permanent Establishments

Finland published Laws 323/2026, 324/2026, and 325/2026 in the Official Gazette on 28 April 2026, which amend the domestic rules on the attribution of profits to permanent establishments based on the Authorized OECD Approach (AOA) as per Article 7 (Business Profits) of the 2010 OECD Model Tax Treaty. This includes the separate entity approach, whereby permanent establishment must be treated as a distinct and independent enterprise for tax purposes. In particular:

• The Income Tax Act is ame…