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Finland Consulting on Revision to Transfer Pricing Adjustment Provision

31 August 2021

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Proposed Changes

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Finland

Finland's Ministry of Finance has launched a public consultation on a draft government proposal to revise the transfer pricing adjustment provision of the Taxation Act so that it can be applied in line with the OECD Transfer Pricing Guidelines, as well as Article 9 of the OECD Model Tax Convention. In these circumstances, the proposed regulation could disregard the related transaction and replace it with another market-based transaction. The proposed revisions are to apply from 1 January 2022. The consultation is open from 23 August to 17 September 2021.