When does a company need to maintain and submit transfer pricing documentation in Finland?
A company is obliged to maintain transfer pricing documentation if at least one of the following is true:
- The company employes at least 250 employees
- Net sales are 50M€ or more AND balance sheet total is 43M€ or more
- The company is not a small or medium-sized enterprise as per EU Commission's definition.
Please note that the figures used in calculating these are the consolidated figures of the whole group. Thus, the documentation obligation often applies to fairly small companies operating in Finland if they are part of a large international group.
The transfer pricing documentation needs to be submitted to the Finnish Tax Administration only upon request.
Even if a company is not obliged to compile a full documentation referred to in the Act on Assessment Procedure, it is recommendable for a multinational enterprise to always document its related party transactions, at least in a free-form manner. Carefully documented information is useful if the company compiles a full documentation or discusses transfer pricing matters with the tax authorities afterwards.