Finland's Proposed ATAD-Compliant Interest Restriction Rules

On 27 September 2018, the Finnish government announced its proposal for new interest deduction restriction rules that are compliant with the EU Anti-Tax Avoidance Directive. Key points of the rules are as follows:

• A general 25% of EBITDA interest deduction restriction will apply for both related and unrelated party debt;
• A EUR 500,000 safe harbor will apply for related party debt (current rule maintained) and a EUR 3 million safe harbor will apply for unrelated party debt (new rule);
• The de…