The Finnish Parliament on 23 November 2016 approved legislation regarding new transfer pricing documentation requirements on country-by-country (CbC) reporting, Master file and Local file measures, and penalty provisions. The documentation requirements are consistent with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project with respect to transfer pricing documentation and CbC reporting.
In Finland, the CbC reporting requirements concern fiscal years starting on or after 1 January 2016. The first CbC notification must be submitted no later than 31 May 2017, if the accounting period has ended before that date.
The new legislation also implements the Council of the European Union’s Directive on Administrative Cooperation (DAC) in the field of taxation concerning the CbC reporting. Under the legislation, the updated transfer pricing documentation rules (including Master file and Local file approaches) as well as regulations implemented under DAC are scheduled to be effective on 1 January 2017.
