Update on the Transfer Pricing Documentation Rules | KPMG | FI

Draft Government Bill regarding Transfer Pricing Documentation and Country-by-Country reporting released

Update on the Transfer Pricing Documentation Rules

The Finnish Ministry of Finance published a draft Government Bill for updating of the transfer pricing documentation rules and introducing the country-by-country reporting (CbCR) for comments on 21 December 2015. The draft Bill includes CbCR, master file and local file requirements and penalty provisions. The contents of the proposed regulations follow the OECD BEPS Action 13 Report on Transfer Pricing Documentation and Country-by-Country reporting.

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MNEs whose global consolidated turnover exceeds EUR 750 million would be obligated to prepare and submit CbCR. The ultimate parent company of a group would be liable to submit the CbCR. However, in cases where the ultimate parent company is a resident of a country which does not require preparing CbCR or the Finnish Tax Administration is not able to receive the information through its information exchange network, the Finnish subsidiary would be liable for submitting the information to the Finnish Tax Administration. Company failing to file the CbCR would be subject to a maximum penalty of EUR 25,000. 

The Ministry of Finance has requested comments on the Draft Bill by 25th of January 2016. The government intends for the provisions to be enacted at the beginning of 2017.

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