Data points
- Group employee count that ends the small and medium-sized exemption[2]
- 250 staff
- Group turnover that ends the exemption, with the balance sheet test[2]
- EUR 50m
- To produce the master file and local file after a request[1]
- 60 days
- Per-counterparty figure below which no comparability analysis is needed[1]
- EUR 500,000
- Ceiling on the punitive tax increase for deficient documentation[1]
- EUR 25,000
- Consolidated revenue that brings country-by-country reporting into scope[3]
- EUR 750m
- After the assessment, the window to adjust transfer prices[6]
- 6 years
Finland frames the documentation duty backwards from most countries. There is no threshold that puts you in. There is an exemption for small and medium-sized groups, and if your group does not qualify for it, you document.
The four facts to know:
- A master file and a local file are required once the group passes the exemption: 250 employees, or turnover above EUR 50 million and a balance sheet above EUR 43 million, measured across the group rather than on the Finnish entity.
- Neither file is filed. You produce both within 60 days of a request, and the request cannot come earlier than six months after the year ends.
- Transactions with a single counterparty under EUR 500,000 in the tax year need no functional or comparability analysis.
- Late or materially deficient documentation costs a punitive tax increase of up to EUR 25,000, even when the pricing itself was right.
What are Finland's latest transfer pricing rules?
Two changes land on tax years beginning on or after 1 January 2022, and both are still catching groups out. The adjustment rule was rewritten, and the tax authority can now disregard or recharacterise a transaction that independent parties would never have entered rather than simply repricing it. Local file content was tightened at the same time, with comparability analysis and financial information required for every counterparty above EUR 500,000.
The Finnish Tax Administration's documentation guidance[1] is the operative text for both files.
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| Requirement | Finland's rule | Source |
|---|---|---|
| Who documents | Groups outside the small and medium-sized exemption | Finnish Tax Administration |
| How the files reach the tax authority | Kept, not filed. Produced within 60 days of a request | Finnish Tax Administration |
| Language | Finnish, Swedish or English | Finnish Tax Administration |
| Documentation penalty | Punitive tax increase of up to EUR 25,000 | Finnish Tax Administration |
Who has to prepare transfer pricing documentation in Finland?
Every group that is not a small or medium-sized enterprise, measured on consolidated group figures rather than on the Finnish entity alone. A three-person Finnish subsidiary of a large multinational documents in full, because the test never looks at the subsidiary. The Finnish Tax Administration sets out when the obligation arises[2].
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| Test, at group level | Threshold | Source |
|---|---|---|
| Employees | 250 or more | Finnish Tax Administration |
| Turnover | Above EUR 50 million | Finnish Tax Administration |
| Balance sheet total | Above EUR 43 million | Finnish Tax Administration |
Whether the exemption falls away for transactions with a counterparty in a jurisdiction Finland has no treaty with is not confirmed against the live statutory wording, so this page does not state it as a rule.
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Do I need a master file in Finland?
Yes, if the group falls outside the exemption and the Finnish entity has cross-border related-party transactions. There is no separate monetary threshold for the master file. The two obligations arrive together, so there is no size band where you owe a local file and not a group one.
A foreign parent's existing master file usually satisfies the Finnish content as written, provided it is available in an accepted language and can be produced inside the deadline. The work that does not travel is the local file.
What does Finland require in the local file?
The entity-level record, with one Finnish simplification worth planning around. Where transactions with a single associated enterprise do not exceed EUR 500,000 in the tax year, that counterparty needs no master file coverage, and the local file needs no functional or comparability analysis for it.
Above EUR 500,000 the full treatment applies: comparability analysis, financial information and the method chosen for each transaction. The split is per counterparty, not per group, so a Finnish entity with many small relationships and one large one does the heavy work once.
Does Finland require country-by-country reporting?
Yes, for groups with consolidated revenue of at least EUR 750 million in the preceding accounting period. The report is filed by the ultimate parent or a surrogate within twelve months of the period end. Finnish resident entities and permanent establishments file a separate notification naming the entity that will report, as the Finnish Tax Administration explains[3].
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| Element | Finland's rule | Source |
|---|---|---|
| Threshold | EUR 750 million of consolidated revenue in the preceding period | Finnish Tax Administration |
| Report | Filed by the ultimate parent or a surrogate, within twelve months of period end | Finnish Tax Administration |
| Notification | Filed by Finnish entities and permanent establishments, by the last day of the reportable accounting period | Finnish Tax Administration |
The notification deadline falls inside the reporting year itself, not after it, which is the one date a foreign parent reliably misses.
Does Finland require a transfer pricing form?
Yes. Form 78, the explanation of transfer prices, goes in with the annual tax return. It is required from any company that has a documentation obligation and transacted with a foreign related party during the tax year, and it is not required where no such transaction happened. The Finnish Tax Administration sets out when the form is due[4].
This is the piece of the Finnish regime that is actually filed on a calendar. The two files behind it are not.
When is Finland transfer pricing documentation due?
On request, with a floor under how early the request can come. The tax authority cannot ask for a given year's documentation until six months after that year ends, and once it does ask, you have 60 days. Supplementary information runs on its own 90-day clock.
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| Obligation | Trigger | Deadline | Source |
|---|---|---|---|
| Master file and local file | A request from the tax authority | Within 60 days, and no request earlier than six months after year end | Finnish Tax Administration |
| Supplementary information | A request from the tax authority | Within 90 days | Finnish Tax Administration |
| Form 78 | Annual filing | With the annual tax return | Finnish Tax Administration |
| Country-by-country report | End of the accounting period | Within twelve months | Finnish Tax Administration |
| Country-by-country notification | End of the reportable period | By the last day of the reportable accounting period | Finnish Tax Administration |
What language and currency does the documentation use?
Finnish, Swedish or English, all three accepted. If you file in English, essential parts have to be translated into Finnish or Swedish where the official handling the case does not read the original. No mandatory presentation currency appears in the guidance, so whether a group-currency master file is accepted as it stands is not confirmed.
What are the penalties for getting Finland transfer pricing wrong?
Documentation failures carry a flat ceiling rather than a percentage, because there is no added income to calculate a percentage against. Late or materially deficient documentation draws a punitive tax increase of up to EUR 25,000, and that is a single combined ceiling for every defect, not a charge per file.
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| Exposure | Finland's rule | Source |
|---|---|---|
| Documentation late or materially deficient | Punitive tax increase of up to EUR 25,000, combined ceiling | Finnish Tax Administration |
| Price not at arm's length | Income adjusted, with a percentage tax increase on the added income | Finnish Tax Administration |
The documentation fine applies even where the pricing itself was correct. The percentage band on an adjustment for 2026 is not confirmed, so this page does not state a number for it.
What is a foreign parent exposed to in Finland?
The fine is the small part. The real exposure is the adjustment, and since the 2022 rewrite the tax authority can disregard or recharacterise a transaction[5] rather than only reprice it. A financing arrangement that no independent party would have signed can be treated as something else entirely.
An adjustment can be made within six years following the assessment, under the control rules in force since 2017[6]. A missing file also moves the burden of proof toward the taxpayer in any dispute, which is the cost nobody budgets for.
Can you get an advance pricing agreement in Finland?
Bilateral and multilateral only. Finland has no separate agreement legislation and no unilateral route, so certainty comes from an agreement reached between two or more treaty states under the mutual agreement article of a tax treaty. The Finnish Tax Administration sets out the procedure[7].
The term is fixed case by case and renewal can be requested. The published guidance carries a 2022 date, so confirm the current position before you plan around it.
How does Finland differ from the OECD baseline?
Finland follows the OECD Transfer Pricing Guidelines as the interpretive source for its arm's length rule, with four practical differences. The duty is framed as an exemption rather than a threshold. There is no separate master file threshold. A EUR 500,000 per-counterparty figure allows a lighter local file. And documentation is produced on request rather than filed. The EUR 750 million country-by-country threshold matches the international standard, so there is no difference there.
How we help with Finland transfer pricing
Finland gives you 60 days to produce a file you were meant to have written already, and the pricing behind it can be recharacterised rather than merely corrected. We write the master file and the local file, build the comparability analysis for every counterparty over EUR 500,000, and file Form 78 with the return. See how our transfer pricing software works.
Book a demo for a readiness check on your Finnish entity before the next request lands.
Official sources
7 sources
- 1.Finnish Tax Administration. Transfer pricing documentation guidance
- 2.Finnish Tax Administration. Obligation to compile transfer pricing documentation
- 3.Finnish Tax Administration. Country-by-country report and notification
- 4.Finnish Tax Administration. When does a company need to submit Form 78
- 5.Finnish Tax Administration. The transfer pricing adjustment provision (siirtohinnoitteluoikaisusaannos)
- 6.Finnish Tax Administration. Transfer pricing guidance and procedures: tax control
- 7.Finnish Tax Administration. Advance pricing agreement guidance
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
