On 22 February 2016, the Finnish tax authority published a notice that it will follow the transfer pricing guidelines developed as part of Actions 8-10 of the OECD BEPS Project as included in the final report Aligning Transfer Pricing Outcomes with Value Creation. These guidelines cover: Guidance for Applying the Arm's Length Principle; Commodity Transactions; Guidance on the Transactional Profit Split Method; Intangibles; Low Value-adding Intra-group Services; and Cost Contribution Arrangements. According to the notice, Finland takes the position that the updated guidance under Actions 8-10 applies from the date the final reports were published (5 October 2015). As such,...