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Finnish Parliament Considering New Rules on the Attribution of Profits to Permanent Establishments

|Proposed Changes|Finland
Finland

The Finnish Parliament is considering draft bill HE 164/2025 vp, which will 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. In particular:

  • The Income Tax Act is amended to introduce more detailed rules on the allocation of profits to permanent establishments in accordance with Article 7 of the 2010 OECD Model when an applicable income tax trea…

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