Seeking amendment for transfer pricing adjustment

This guidance will be updated.

A claim for adjustment of a transfer pricing adjustment can be made to the Board of Adjustment. The claims for adjustment are prepared by the Transfer Pricing Unit of the Finnish Tax Administration. The decision of the Board of Adjustment can be appealed against to the administrative courts.

Processing the claim for adjustment

The taxpayer and the Tax Recipients' Legal Services Unit may submit a written claim for adjustment to the Board of Adjustment in cases involving transfer pricing matters (regarding regular tax assessment or tax adjustment).

If the taxpayer submits a claim for adjustment concerning a transfer pricing adjustment, the Transfer Pricing Unit of the Finnish Tax Administration reassesses the basis for the earlier transfer pricing adjustment. The case handler may request additional information from the taxpayer. After reassessing the case, the Finnish Tax Administration may in certain situations accept the claim for adjustment on the basis of the new information presented in the claim for adjustment or new case law concerning the matter.

If the Finnish Tax Administration does not accept the claim for adjustment submitted by the taxpayer, the matter will be resolved by the Board of Adjustment. The Transfer Pricing Unit prepares the claims for adjustment concerning transfer pricing and presents them to the Board of Adjustment. The case handler and the Board of Adjustment may request additional information from the taxpayer.

The decision of the Board of Adjustment may be appealed against

The taxpayer and the Tax Recipients' Legal Services Unit may appeal against the decision of the Board of Adjustment to the Administrative Court and against the Administrative Court decision to the Supreme Administrative Court, if the Supreme Administrative Court grants a leave to appeal.