Finland Open to Early Transfer Pricing Discussions

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By Penny Sukhraj

Aug. 16 — The Finnish Tax Administration (Vero Skatt) is advising multinationals of the option for quick advanced discussions to establish transfer pricing positions.

In a notice published Aug. 15, Vero Skatt said the administration is offering “the possibility to examine the tax position flexibly in advance” so that companies can avoid “unexpected tax consequences.”

The administration said further that court decisions concerning tax disputes have also previously upheld decisions from the tax administration.

Noting that transfer pricing issues are usually “always complex and far-reaching in nature” with clearance post their arrangement also “often laborious and slow” the tax administration said that companies have the option to request early discussions on their transfer pricing issues, or obtain preliminary ruling.


Vero Skatt said it completed 56 transfer pricing tax audits since 2012, each of which lasted an average of two years. Cases that go beyond the average are usually referred to court, the notice said.

While some matters are difficult due to their complexity and the necessary checks needed to verify arrangements, some are slowed due to the time taken to obtain further information from the companies involved.

Appealing Vero Skatt Decisions

Companies that aren't satisfied with the tax administration's assessment can appeal before the Tax Administration Board of Adjustment, or later to the Administrative Court, and finally the Supreme Administrative Court.

Between 2010-16 companies have successfully challenged Vero Skatt transfer pricing assessments. These have resulted in 21 transfer pricing court settlements, the government said. Of these, 11 fully maintained Vero Skatt's decision while seven upheld the government in part. Decisions of the tax administration were reversed in three cases, the government said.

To contact the reporter on this story: Penny Sukhraj in London at

To contact the editor responsible for this story: Rita McWilliams at

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