Finland Transfer Pricing Documentation Requirements
Finland requires a Master File and Local File from groups that do not qualify as small or medium-sized enterprises, produced within 60 days of a request, and a separate Form 78 disclosing cross-border intra-group transactions is filed with the annual tax return. The documentation penalty is capped at EUR 25,000 and can apply even where pricing is at arm's length.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Non-SME groups: ≥ 250 employees, or net sales > EUR 50m and balance sheet > EUR 43m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 60 days. | FI / SV / EN | Yes (maximum EUR 25,000 even for multiple failures) |
Local File Required | Same non-SME test as the Master File | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 60 days. | FI / SV / EN | Yes (maximum EUR 25,000 even for multiple failures) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
The Finnish documentation requirement applies to entities that are not treated as small or medium-sized enterprises. An entity is outside the SME category, and therefore within the requirement, where the consolidated ultimate parent meets one of the following: at least 250 employees, or net sales above EUR 50 million combined with a balance sheet total above EUR 43 million, or where the SME criteria in the relevant European recommendation do not otherwise apply. Documentation in the OECD Master File and Local File format satisfies the Finnish requirements, and it is produced within 60 days of a request.
Distinctive features of the Finnish regime
The distinctive feature of the Finnish regime is the structure of its penalty. A documentation penalty of up to EUR 25,000 may be levied, and that maximum is a single cap that applies even where there are multiple failures across the documentation. Significantly, the penalty can be levied even where the transfer prices themselves are at arm’s length, if the taxpayer has failed to provide documentation on time or has provided insufficient or inaccurate information, so the obligation is treated as a freestanding compliance duty rather than only a consequence of mispricing. Alongside the documentation, Form 78 must be completed and filed with the annual corporate income tax return, reporting cross-border intra-group transactions that do not appear directly in the financial statements, though it does not capture the method applied.
Benchmarking and comparables
There are no specific regulations on the preparation of benchmarking studies, but local or Nordic comparables are preferred, with pan-European comparable sets generally accepted in practice. Multi-year analysis, typically over three years, is the common approach. A fresh benchmarking search is not required every year. The limitation period for an income adjustment based on the arm’s length principle is six years after the end of the calendar year in which the financial statements were closed.
Frequently asked questions
Can a Finnish taxpayer be penalised even if its transfer prices are correct?
Yes. The documentation penalty of up to EUR 25,000 can be levied where documentation is late, insufficient, or inaccurate, even if the underlying transfer prices are at arm's length.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.