On 21 August 2021, the Finland’s Ministry of Finance has launched a public consultation on draft bill concerning the revision of the Finnish transfer pricing adjustment provision.

The draft law includes measures that: 1) align the determination of the transfer pricing adjustment with the OECD Transfer Pricing Guidelines and Article 9 of the OECD Model Tax Convention; and 2) allow certain transactions to be ignored and replaced with another market-based transaction. The proposed revisions will be applied from 1 January 2022. Comments are due 17 September 2021.