The Ministry of Finance on 21 December 2015 released for public comment a proposal to revise the transfer pricing documentation rules and introduce country-by-country (CbC) reporting.
The proposed legislation would follow the three-tiered approach to transfer pricing documentation requiring multinational enterprises (MNEs) to prepare (i) a Master file containing standardised information relevant for all MNE group members; (ii) a Local file referring specifically to material transactions of the Finnish taxpayer; and (iii) a CbC Report containing certain information relating to the global allocation of the MNE’s income and taxes paid together with certain indicators of the location of economic activity within the MNE group.
The Ministry of Finance has requested comments be submitted by 25 January 2016. The government intends for the provisions to be enacted and effective beginning 2017.
