Finland Tax Agency Issues Guidance on Application of OECD Guidelines to Domestic Transfer Pricing Rules

The Finnish Tax Administration Dec. 17 issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective Dec. 31. Topics covered include that: 1) the guidelines can be used for interpreting market pricing conditions; 2) the guidelines act as a primary source of interpretation for intra-group financial transactions, effective tax year 2020; 3) the reclassification of transactions is allowed under specific circumstances; 4) a parent company’s credit rating can be used to determine the creditworthiness of individual group companies for future and renegotiated financial transactions; 5) the updated guidelines must be considered for ...