Finland looks to limit the deductibility of interest

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Finland looks to limit the deductibility of interest

finland2.jpg

The Finnish government has released a draft bill to limit the deductibility of interest expenses in corporate taxation. The goal of the proposed regulation is to secure Finland's tax base and to balance competition between domestic and foreign groups of companies

juusela.jpg

Janne Juusela

Interest expenses are widely deductible in business taxation and only applying the transfer pricing regulation or the general provision for tax avoidance can restrict deductibility. Applying the new proposed limitation will not require any intention of tax avoidance or deviation from the arm's-length principle, but it will be applicable as a general rule. According to the draft, limitations would be applicable to corporations, partnerships, corresponding foreign entities and their permanent establishments in Finland. The limitations would be applied only if the interest expenses exceed the interest income received by the company, as in if the company has net interest expenses.

Interest paid to a related party would become non-deductible if the net interest expenses exceed 30% of the company's EBITDA. In the proposed regulation, group contributions would be included in EBITDA.

The related parties are defined similarly as in the Finnish transfer pricing regulation. This means that parties are deemed to be related, if the other party has directly or indirectly control over the other.

Also interest paid to a third party could be regarded as a related party interest in situations such as back-to-back arrangements or when a related party has secured a third party loan with a collateral. Applying limitations in these indirect situations would require a connection between the interest paid to the third party by the debtor and the collateral given to the third party by the related party.

According to the draft, a general safe haven of always deductible €500,000 ($650,000) would apply. This amount would include all interest expenses, whether paid to related parties or not.

The proposed regulation would allow an indefinite carry forward of non-deductible interest expenses. The use of the interest carried forward would require unused EBITDA in the fiscal year of use. Change of ownership would not affect the possibility to carry non-deductible interest expenses forward.

Janne Juusela (janne.juusela@borenius.com)

Borenius – Taxand

Tel: +358 9 615 333

Website: www.borenius.com

more across site & shared bottom lb ros

More from across our site

It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Gift this article