מחירי העברה: פינלנד- פברואר 2010
09 פברואר 2010
Finland introduced transfer pricing regulations, including documentation rules, on 1 January 2007. A taxpayer has to produce written documentation annually on transactions with related parties where the other party is foreign and on transactions between a foreign enterprise and its Finnish permanent establishment.
Small and medium-sized enterprises are not obliged to produce written documentation.
Such an enterprise is defined as an enterprise with fewer than 250 employees, a turnover of no more than EUR 50 million and a balance sheet total not exceeding EUR 43 million. It also has to fulfil certain criteria pertaining to the definition of a micro, small and mediumsized enterprise in the European Commission Recommendation 2003/361/EC.
The following information must be provided in the documentation:
- description of the business
- description of relations with related parties
- clarification of transactions between related parties
- functional analysis on all transactions between related parties
- comparability analysis including the available information on points of comparison
- description of the transfer pricing method and its application. Methods to arrive at correct transfer pricing should be based on the methods outlined by the OECD Guidelines
If the total annual amount of transactions between a taxpayer and the other party is less than
EUR 500 000, the information mentioned in points 4–6 above is not required.
A taxpayer must present its transfer pricing documentation within 60 days of a request from the tax authorities but no earlier than six months from the end of the last month of the accounting period.
Additional and supplementary documentation, for instance information on comparable enterprises, must
be presented within 90 days of a request from the tax authorities. All these time limits can be extended.
The Finnish tax authorities have been quite active in monitoring transfer pricing issues after the launch of the rules. Since the rules have been in effect for a short time only, there are no relevant law cases from the administrative courts yet.
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