Notification of the Reporting Entity – instructions for Lomake.fi

Table of contents

1 Notification of the Reporting Entity
   1.1 First find out what your group’s ultimate parent entity’s reporting requirements are
   1.2 Collect facts and information about the party filing the CbC Report
2 Some definitions
   2.1 Ultimate Parent Entity
   2.2 Reporting Entity
   2.3 Surrogate Parent Entity
   2.4 Secondary Reporting Entity
   2.5 TIN
   2.6 Tax jurisdiction
3 List of details to give
   3.1 The filer submitting this report
   3.2 Reporting role
   3.3 Fiscal year (=Accounting period)
   3.4 CbC Report filer’s identification
   3.5 Other Constituent Entities located in Finland
   3.6 Sending the Notification
4 Deleting a submittal that you sent earlier
5 Making corrections to a Notification submitted earlier

1 Notification of the Reporting Entity

Country-by-Country reporting involves two reports:

  • The notification of the reporting entity – this indicates the identity of the party that has the obligation to file the report
  • The country-by-country (CbC) report – For more information, see: Country-by-Country reporting

All group companies and permanent establishments located in Finland must file the Notification if they are part of a multinational enterprise group with at least €750,000,000 of turnover on its consolidated profit-and-loss account.

Notifications of the Reporting Entity can be filed electronically on the fillable web form via Lomake.fi or as a software-generated file via Ilmoitin.fi. The instructions on these pages are for the fillable web form only.

For more information on e-filing, visit tax.fi: Country-by-country reporting.

1.1 First find out what your group’s ultimate parent entity’s reporting requirements are

When you are planning to submit the Notification of the Reporting Entity, you must first find out whether the Ultimate Parent Entity of your group must submit a CbC Report in its tax jurisdiction, its country of tax residence. The above question is also asked of you when you fill out the web form. It is commonly required of ultimate parent entities that they submit a CbC Report to their country’s tax authorities. Member companies of MNE groups, subsidiaries, and permanent establishments located in Finland only have submit country-by-country reports to the Finnish Tax Administration in exceptional situations.

If the circumstances are unclear, we recommend that you first contact your Ultimate Parent Entity to ascertain which one of your MNE group companies must submit the reports. You can also contact the Tax Administration by e-mail if necessary: siirtohinnoittelu(a)vero.fi

1.2 Collect facts and information about the party filing the CbC Report

For preparing the Notification, you must have:

  • The name and Business ID of the group company (the parent) that files the CbC Report
  • Name of the country that receives the CbC Report
  • The foreign ID code of the filer if the foreign (parent) company is filing the CbC Report

Where “foreign ID” is mentioned, it means an identity code that the foreign company uses on its income tax returns in its country, and for other purposes, or an identity code issued for the needs of a foreign tax authority’s e-file service.

If you are filing the report on behalf of other subsidiaries located in Finland, fill in the space at the web form’s end to specify the other subsidiaries or group companies. To fill in that space, you must have the company names and the Business IDs. You do not need a Suomi.fi authorisation from the other companies for filing the report on their behalf.

2 Some definitions

2.1 Ultimate Parent Entity

A company that must prepare consolidated financial statements under the Accounting Act – or under similar provisions of law, applicable in other tax jurisdictions or countries. Alternatively, the Ultimate Parent Entity is a company that would have to prepare the consolidated financial statements if its equity interests were publicly traded at stock exchanges in the tax jurisdictions where it is resident. It is also required that the Ultimate Parent Entity is not directly or indirectly controlled by another entity that would have to prepare consolidated financial statements.

2.2 Reporting Entity

The Ultimate Parent Entity is the party carrying responsibility for submitting the reports, i.e. the Reporting Entity.

2.3 Surrogate Parent Entity

The group company that the Ultimate Parent Entity has designated as the company filing the CbC Report. Surrogate Parent Entities must file the report to their tax jurisdiction of residence, i.e. to their country.

The international term Surrogate Parent Entity indicates that it acts on behalf of the parent company.

The e-filed reports addressed to the Finnish Tax Administration refer to the Surrogate Parent Entity, and to the designated group company, with the Finnish words “nimetty selvitysvelvollinen”.

2.4 Secondary Reporting Entity

This is a Finnish subsidiary or a Finnish-located permanent establishment that has the responsibility to submit the entire CbC Report information (not just its own company details) to the Finnish Tax Administration. Responsibility for submitting the report can be reassigned from a parent, if exceptional circumstances prevail, to its Finnish subsidiary or permanent establishment. For example, if the parent is foreign and does not have to submit a country-by-country report to the tax authority of its country of domicile, and the parent has not designated a group company as a Surrogate Parent that would assume responsibility for reporting in a country with which Finland has an agreement on information exchange.

2.5 TIN

TIN stands for “Tax Identification Number”. Finnish businesses and any foreign companies that are treated as having a permanent establishment in this country must use their Finnish Business ID instead. If the party filing the report is a foreign company, (a parent), fill the “Foreign ID code” space with its foreign ID code that is similar to the Finnish Business ID.

2.6 Tax jurisdiction

For purposes of this guide, this term refers to the country of tax residence of the company filing the CbC Report – often the Ultimate Parent Company’s country.  The tax jurisdiction country may be Finland – in this case, the company must send its CbC Report to the Finnish Tax Administration.

3 List of details to give

3.1 The filer submitting this report

Fill in the information concerning the company that submits the Notification of the Reporting Entity, i.e. information on the company that completes the web form. The company’s Business ID and name appear automatically, according to the login information in the e-service.

In addition, give the name of a person to contact, who can be contacted if we need further information.

Please note: If the name and Business ID of the company submitting the report do not appear automatically, make sure to check that you selected “I am submitting information for a company”, not your personal information. If you need to change this setting, go to “Change taxpayer” on the top of the page. You can change the setting if you have the authorization to submit the report on the company’s behalf.

3.2 Reporting role

The company that submits the Notification should select its role, which depends on whether or not the company files a CbC Report to Finland.

The most frequently occurring selection is “None of the above”, in other words, the company that submits the Notification files no CbC Report.

If the company submits a CbC Report in Finland, select one of the 3 other options:

  • Your company is the Ultimate Parent Entity and your tax jurisdiction is Finland.
  • Your company is the parent-designated filer of the CbC Report, and the tax jurisdiction of the group’s ultimate parent entity is not Finland – select Surrogate Parent Entity.
  • Secondary Reporting Entity, if your company is required to file the CbC Report in Finland.

Example 1: Your company is a subsidiary located in Finland. The tax jurisdiction of your group’s ultimate parent entity is Sweden.

The Swedish parent must file its CbC Report to the Swedish Tax Agency which in turn will send it on to the Finnish Tax Administration.

The role selection that you as the Finnish-located subsidiary must make is “None of the above”.

The none-of-the-above role should also be selected by Finnish-located subsidiaries and permanent establishments in multinational enterprise groups that have Finland as the tax residence of the Ultimate Parent Entity.

Example 2: Your company is a subsidiary located in Finland. The tax jurisdiction of your group’s ultimate parent entity is the “X” country.

The foreign parent entity does not have an obligation to file a CbC Report to the tax authorities of “X”, its tax jurisdiction. For this reason, the parent has designated its German subsidiary as the Surrogate Parent Entity that sends the CbC Report to the tax authority of Germany.

The role selection that you as the Finnish-located subsidiary must make is “None of the above”.

Example 3: Your company is the Ultimate Parent Entity and your tax jurisdiction is Finland.

You, the group’s ultimate parent entity must file the CbC Report to the Finnish Tax Administration.

The role to select is “Ultimate Parent Entity”.

Example 4: Your company is a subsidiary located in Finland. The tax jurisdiction of your group’s ultimate parent entity is the “X” country.

The foreign parent entity is not required to file a CbC Report to the tax authorities of “X”, its tax jurisdiction country. The foreign parent, i.e. the Ultimate Parent Entity, has designated the Finnish subsidiary as the Surrogate Parent Entity. In this case, it must file the reports in Finland on behalf of the entire group.

The role for you to select is “Surrogate Parent Entity”.

3.3 Fiscal year (=Accounting period)

Indicate the start and end dates of your group’s ultimate parent entity’s fiscal year.

Illustration: This way, if the ultimate parent’s fiscal year is the calendar year, and your CbC Report is for 2018, enter:

2018-01-01     2018-12-31

3.4 CbC Report filer’s identification

Business ID and name

Fill in the Finnish Business ID or the foreign ID code of the company that submits the CbC Report.

  • If a Finnish company, (a parent that is Finnish) or a permanent establishment located here submits the CbC Report, fill in its name and Finnish Business ID.
  • If a foreign company, (your MNE group’s parent) submits the CbC Report, fill in its name and foreign ID code (TIN, the Tax Identification Number). If no TIN is available, give another identity code by which the company can be identified.

Type the CbC Report filer’s company name.

Example 5: Your company is a subsidiary located in Finland. The tax jurisdiction of your group’s ultimate parent entity is Sweden.

The Swedish ultimate parent entity must file the CbC Report to the Swedish Tax Agency.

You as the Finnish subsidiary must fill in the Swedish parent’s name. Accordingly, fill in the Swedish parent’s ID code (organisationsnummer) under “Foreign ID code”.

Tax jurisdiction

You must indicate the country where the national tax authority will receive the CbC Report. This is the tax jurisdiction.

  • In the circumstances described above in Example 2, you should select “Germany” because the report is filed there. In the circumstances described above in Example 5, you should select “Sweden” instead.

Role of the party filing the CbC Report

If your role when submitting the Notification is “none of the above”, i.e. your company files no CbC Report to Finland, you must specify the role of the party that does file it:

  • Ultimate Parent Entity – select this if your group’s ultimate parent files the CbC Report.
  • Surrogate Parent Entity - select this if you are the group company that the Ultimate Parent Entity designated as the company filing the CbC Report.

Example 6: Your company is a subsidiary located in Finland. The party responsible for filing the CbC Report is the group’s ultimate parent company. Its tax jurisdiction is Sweden.

You, the Finnish subsidiary, must select Ultimate Parent Entity as the Swedish parent’s role.

Example 7: Your company is a subsidiary located in Finland. The foreign parent entity does not have to file a CbC Report to the tax authorities of its country of tax residence.

For this reason, the parent has designated its German subsidiary to provide the CbC Report to the tax authority of Germany.

You, the Finnish subsidiary, must select Surrogate Parent Entity as the role of your group’s subsidiary in Germany.

Optional description

You can fill in further details about the Notification in this space. An example of an optional description would be that your multinational enterprise group has been sold to a new owner part way during the accounting year, meaning that your group’s Ultimate Parent Entity has changed, and the company that bears responsibility for CbC Reports is now a different company than previously.

3.5 Other Constituent Entities located in Finland

If you file the Notification of the Reporting Entity in a centralized manner not only on your company’s behalf but also on other Finnish-located subsidiaries’ behalf, fill in the relevant information.

  • The meaning of “Constituent Entities” in this guide is that they are the entities to be covered by the CbC Report, i.e. the report must contain information on these subsidiaries. A group may have several Constituent Entities in Finland that must be included in the report content.
  • The section below is intended to make the reporting requirement simple when a CbC Report must contain more than one Finnish-located group entities or permanent establishments. It is enough if just one of the Finnish entities – a subsidiary or a permanent establishment – gives the details on all the other entities located in Finland. There is no need for you to repeat the information you already gave about the party filing the report.

 

Example 8: Finland is the tax jurisdiction of a multinational enterprise group’s ultimate parent entity. The Finnish parent wants to file on behalf of all Finnish-located subsidiaries and permanent establishments.

Accordingly, the parent company should enter the Business IDs and names under “Constituent Entities resident in Finland”. There is no need for the parent to repeat its own information here.

Example 9: “X Limited” is the foreign Ultimate Parent Entity of a multinational enterprise group and it must file a CbC Report to the authorities of its tax jurisdiction country. The Finnish “A” and “B” are group subsidiaries. Both of them must provide a Notification of the Reporting Entity.

In this case, “A” files its Notification of the Reporting Entity, stating that “X Limited” will file a CbC Report in its tax jurisdiction country. In addition, “A” indicates that “B”, a Finnish company, is also a subsidiary of the group. As a result, there is no need for “B” to file a report at all. When completing the form, “A” fills in “B’s” name and Business ID under “Constituent Entities resident in Finland”.

However, if “A” does not do this, “B” must file a report of its own. This means that “B” completes the form with information on “B” only, and it must leave “Constituent Entities resident in Finland” blank.

3.6 Sending the Notification

After your Notification of the Reporting Entity is completed, click on the Send button to send it. No acknowledgement-of-receipt message will arrive to you. However, you can check your Notification’s current status in My e-Services. If you sent the Notification successfully, the word "Submitted” appears next to its name.

To save an unfinished fillable web form in order to continue working on it some time later, click on “Save” in “My e-Services”. No information is yet being sent to the Tax Administration. You can come back later to fill in more spaces.

To reset the entire web form and to not send it, click on Cancel.

You can click on the Print (Tulosta) button to get a paper copy of the completed form before you submit or save it. Note: to click on the Print (Tulosta) button does not mean that you save any information or send any information to the Tax Administration.  In other words, to get a paper printout does not mean that you have received the Finnish Tax Administration’s acknowledgement of receipt.

4 Deleting a submittal that you sent earlier

To delete a Notification, report, etc., that you sent at an earlier date, send a “Deletion report”. For example, you could delete a Notification that you submitted earlier if you were to notice that it contained a Business ID of a different company, not the company that should actually file it. Note: to send a Deletion report only means that you are removing a Notification, report, etc. from the database. You cannot use the Deletion report to make changes and corrections.

  1. Go to My e-Services.
  2. First, look up the Notification, report, etc. that you need to delete.
  3. Click on “Use as base” to open it.
  4. Go to Deletion report, and then select “Yes”.

  1. Click on Send.

5 Making corrections to a Notification submitted earlier

To make corrections to a previous Notification, report, etc., send a “Correction report”.

  1. Go to My e-Services.
  2. First, look up the Notification, report, etc. that you need to make corrections to.
  3. Click on “Use as base” to open it.
  4. Make the necessary corrections. The Correction report will show the corrections you enter.
  5. Click on Send.