There are two substance-based carve-outs/exemptions; 1) one applying to entities within the EEA and 2) the other applying to entities in countries outside the EEA. 
According to the first rule, the CFC rules do not apply if the entity is genuinely established in the jurisdiction and in fact carries on actual business there (substantive economic activity).

According to the second rule, the same applies also to non-EEA entities but in that case, also three additional requirements must be met. These are as follows: (i) the state of residence cannot be in the EU’s so-called 'black list', (ii) Finland must have an active agreement on the exchange of information in tax matters with the country in question, and (iii) the foreign entity must carry out business activities that are covered by the business line exception. The business line exception covers mainly industry and production and certain kinds of services.