The Tax Office has indicated how it is dealing with the Supreme Court ruling declaring the tax interest rate to be non-binding. See also our article Vpb tax interest non-binding.
16 January 2026
The crucial date, of course, is the one when the Supreme Court handed down its judgment: 16 January 2026. The Tax Authority indicates that tax interest charged on assessments with a date after 16 January 2026 will be reduced ex officio. This means that although the tax interest charged on the assessment is too high (the software cannot be adjusted at such short notice), the Tax Administration will take the initiative to reduce it.
Reject
The Tax Administration says it will reject requests for ex officio reduction of tax interest on corporate tax assessments that were irrevocably fixed on 16 January 2026. Tax assessments with a date before 5 December 2025 were irrevocably fixed on 16 January 2026, except when objected to (pro forma) before 16 January 2026.
Notices of objection (pro forma) filed against charged tax interest will be finalised by the Inland Revenue within 6 months of the Ministry of Finance ruling on the mass objection (that ruling is due by 26 February 2026).
Not irrevocable
Tax assessments with a date in the period from (and including) 5 December 2025 to 15 January 2026 do not need to have been objected to in time (pro forma) in order to have tax interest reduced. After all, those assessments were not yet irrevocably fixed at the time of the Supreme Court's ruling. However, a request for an ex officio reduction may still have to be submitted for those assessments.