On 8 February 2023, the Finnish tax administration issued guidance No.VH/5942/00.01.00/2022 on the application of OECD transfer pricing guidelines to domestic transfer pricing rules. The purpose of the guidance is also to summarize the effects of the amendment to § 31 VML (1142/2021) and the related government proposal (HE 188/2021 vp) on the use of transfer pricing guidelines as a source of interpretation.

The guideline applies to tax years beginning on or after 1 January 2022.