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

The second Draft Government Bill about CbC reporting

The Finnish Ministry of Finance released the Draft Government Bill for public comments to amend Finnish Transfer Pricing Documentation requirements as well as to introduce Country-by-Country (CbC) Reporting.


The Draft Bill published includes CbC Reporting, Master file and Local file requirements as well as penalty provisions that are consistent with the Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project with respect to Transfer Pricing Documentation and CbC Reporting. For more information, please see our Tax Newsflash published 11st of January 2016.

In addition, the Draft Bill proposes actions to implement Council of the European Union’s Directive on Administrative Cooperation (DAC) in the field of taxation concerning the CbC Reporting into Finnish legislation.

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 Directive are proposed to be effective on 1 January 2017.



Jarno Mäkelä T. +358 20 706 3858


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