Finland: Transfer pricing, CbC draft legislation | KPMG | BE

Finland: Transfer pricing documentation, country-by-country reporting draft legislation

Finland: Transfer pricing, CbC draft legislation

The Ministry of Finance released for public comments, a draft bill that would amend Finnish transfer pricing documentation requirements as well as introduce country-by-country (CbC) reporting.


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The draft bill includes measures that would require CbC reporting, and Master file and Local file requirements (and would establish penalty provisions) consistent with the recommendations under Action 13 of the OECD base erosion and profit shifting (BEPS) project.

In addition, the draft bill proposes to transpose the EC's Directive on Administrative Cooperation (DAC) into Finnish law.

Effective date provisions

As proposed, CbC reporting would concern fiscal years starting on or after 1 January 2016. Updated transfer pricing documentation rules including Master file and Local file approaches as well as regulations implemented under the EC directive are proposed to be effective 1 January 2017.


Read a June 2016 report prepared by the KPMG member firm in Finland

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