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.

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