Finnish TP-Legislation updated to include non-recognition and recharacterisation

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Effective as of 1. January 2022 Finnish Transfer Pricing legislation has been updated to align the rules with the OECD Transfer Pricing Guidelines in regards to non-recognition and recharacterisation.

Going forward the arm’s length provision in the Tax Procedure Act, section 31, will include the possibility for non-recognition and recharacterisation which according to Finnish Case Law has not been possible under the previous wording of the provision.

Case NameDescriptionDateCountriesKeywords

 

Unofficial Translation of New Finnish Transfer Pricing Legislation on Non recognition and Recharacterisation in Section 31 of the Tax Procedure Act

TP-Guidelines