Finland: Country-by-country reporting | KPMG | GLOBAL
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Finland: Country-by-country reporting, Master file, Local file requirements

Finland: Country-by-country reporting

The Finnish Parliament on 23 November 2016 approved legislation providing for new transfer pricing documentation requirements—country-by-country (CbC) reporting, Master file and Local file measures, and penalty provisions—that 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.


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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.

CbC reporting

In Finland, the CbC reporting requirements concern fiscal years starting on or after 1 January 2016. Finnish entities belonging to a taxpayer group that is required to file a CbC report will need to notify the Finnish tax administration as to which member of the group will file the CbC report. 

  • The first CbC notification must be submitted no later than 31 May 2017, if the accounting period has ended before that date. 
  • After the first year, the CbC notification must be submitted by the end of accounting year to be reported. 
  • CbC reports must be filed within 12 months after the end of accounting period to be reported.

The Finnish tax administration may issue more detailed guidance regarding the CbC reporting and transfer pricing documentation.


For more information, contact a tax professional with the KPMG member firm in Finland: 

Juha Jääskeläinen | +358 20 760 3032 |

Suvi Vasenius | +358 20 760 3241 |

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