Transfer pricing in Finland

Transfer pricing in Finland at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? Yes
Submission deadline No earlier than 6 months after the end of the financial period
Submission deadline upon request 60 days
Annual update required No
Official language requirements Finnish, Swedish and English
Potential impact of penalties Up to 25K

 

Finnish tax law

Rules for transfer pricing in Finland are based upon:

  • Finnish Tax Act on Assessment Procedure §14 a-c, 31, 32, 75 and 89
  • Government Proposal and Tax Administration’s Guidelines of 19 October 2007

OECD

Rules for transfer pricing in Finland follow the OECD Transfer Pricing Guidelines.

Methods

Accepted methods

Accepted methods are:

  • the comparable uncontrolled price method;
  • the resale price method;
  • the cost plus method;
  • the profit split method, and
  • the transactional net margin method.

Priority of methods

Rules for transfer pricing in Finland do not prescribe a priority of method.

Documentation requirements

Information that should be included in the documentation: 

  • A description of the business;
  • A description of associated enterprises;
  • Information on transactions between associated enterprises;
  • Functional analysis regarding transactions between associated enterprises;
  • A comparability analysis, including available information on comparables, and
  • A description of the transfer pricing method and its application.

Language

Rules for transfer pricing in Finland prescribe that documentation should be submitted in either one of the following languages:

  • Finnish
  • Swedish
  • English

Requirements to prepare documentation annually

There is no formal requirement to prepare documentation annually, however, it is recommended.

Submission deadline upon request by tax authorities

Upon request of the tax authorities, a taxpayer should submit its documentation within 60 days after a request has been made.

Advanced Pricing Agreements

General

Rules for transfer pricing in Finland do no provide for specific Advanced Pricing Agreement procedures.

Terms

Not applicable.

Penalties

Rules for transfer pricing in Finland provide for a penalty of EUR 25,000 if a taxpayer fails to comply with the transfer pricing documentation requirements.

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