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Finland Issues Guidance on Updates to the OECD Transfer Pricing Guidelines as Sources of Interpretation

27 April 2021

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Approved Changes

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Finland

The Finnish tax administration has published guidance regarding updates to the OECD Transfer Pricing Guidelines (TPG) as a source of interpretation in applying Finland's transfer pricing rules under Section 31 of the Tax Procedures Act (VML) The guidance provides that decisions of the Supreme Administrative Court concerning transfer pricing guide the application of Section 31 of the VML. Thus, updates to the TCG may be taken into account in the interpretation of Section 31 to the extent that they do not contradict the case law of the Supreme Administrative Court. Further, based on domestic case law, the clarifications presented in...