At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Verohallinto (Finnish Tax Administration). Summaries are simplified; check the linked official source before relying on them.
The law
#Section 31 of the Act on Assessment Procedure (Verotusmenettelylaki 1558/1995, VML) is the arm's length rule. If related parties agreed terms that differ from what independent parties would agree, and taxable income came out lower, the missing amount is added to income. Since the 2021 amendment (1142/2021) the section follows the OECD ideas of accurate delineation, and in exceptional cases a transaction can be disregarded and replaced (s. 31(2) and (3)). The rule also covers dealings between a company and its permanent establishment. The Tax Administration (Verohallinto) guidance on documentation (VH/44/00.01.00/2022) relies on the OECD Transfer Pricing Guidelines.
Documentation
#Large companies must prepare a written transfer pricing documentation on transactions with foreign related parties (s. 14 a VML). SMEs are exempt: fewer than 250 employees, turnover of at most EUR 50m or balance sheet total of at most EUR 43m, and independence under EU Recommendation 2003/361. Group figures count. The content follows the master file and local file split (s. 14 b). Transactions of EUR 500,000 or less per related party a year need lighter content. The documentation is not filed with the return. It must be handed over within 60 days of a request, but not for a year until six months after the end of the month in which the year ends, and supplementary information such as comparables is due within 90 days (s. 14 c). Verohallinto may extend these times on request. It may be in Finnish, Swedish or English.
Methods
#The VML names no methods. Verohallinto's guidance follows the OECD Guidelines: traditional methods are the comparable uncontrolled price, resale price and cost plus methods, and profit methods are the transactional net margin and profit split methods. The documentation must describe the method and how it was applied (s. 14 b(2) point 7). A comparability analysis with information on comparables is part of the local file content.
Penalties
#If the documentation or supplement is late, or has essential gaps or errors, Verohallinto imposes a tax increase (veronkorotus) under s. 32(1) point 2. The same applies to late or wrong CbC filings (point 3). The basic rate is 2 per cent of the added income, and 3 to 10 per cent if the failure is repeated or shows obvious disregard. For documentation and CbC failures the increase is capped at EUR 25,000 (s. 32 a(8)). It is not imposed if the failure is minor or has a valid reason. Lower rates apply to voluntary corrections.
Pillar Two
#The Minimum Tax Act (laki suurten konsernien vähimmäisverosta 1308/2023) covers groups with annual revenue of at least EUR 750m in at least two of the four preceding years. It applies to years that start on or after 31 December 2023 and includes the income inclusion rule and a domestic top-up tax. The undertaxed profits rule applies from years starting on or after 31 December 2024, with an exception for groups with a parent in an EU state that used the deferral option. The top-up tax information return, the top-up tax return and the notice of who files the information return are all due 15 months after year end, or 18 months for the group's first transition year. Verohallinto assesses the tax, and the payment date is the due date in the tax decision (s. 12 Tax Collection Act). Late filing fees are EUR 5,000 for the information return and EUR 1,000 for the other filings. Missing or wrong returns can bring a tax increase, usually 10 per cent of the extra tax and 15 to 50 per cent for repeated failures or obvious disregard, with a minimum of EUR 10,000 (ch. 8 s. 16). None is imposed in the transition period (years starting by 31 December 2026 and ending by 30 June 2028) if the group made a careful good faith effort.
Other rules
#Groups with consolidated revenue of at least EUR 750m file a CbC report in OmaVero within 12 months of the end of the year, and each Finnish entity notifies Verohallinto by the last day of the year (s. 14 d VML). The company income tax return is due four months after the end of the month in which the year ends. A deadline on a Saturday, public holiday, May Day, Independence Day, Christmas Eve or Midsummer Eve moves to the next working day (s. 5 of the Act on the Calculation of Statutory Time Limits). Finland has no separate transfer pricing return form.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC notification (ilmoitus maakohtaisen raportin antajasta) Each Finnish entity tells Verohallinto whether it is the ultimate parent, the surrogate filer or neither, and if neither, names the reporting entity and its country. It is due by the last day of the financial year being reported (s. 14 d(9) and (11) VML). It is filed in OmaVero. Under s. 5 of the Act on the Calculation of Statutory Time Limits a date on a weekend or holiday moves to the next working day, but filing before year end is safest. Late or wrong notification can bring a tax increase of up to EUR 25,000. | Last day of the fiscal year (e.g. Dec 31, 2025) | Finnish group entities and permanent establishments in groups with consolidated revenue of at least EUR 750m in the previous financial year and at least one foreign group party. | s. 14 d Act on Assessment Procedure (Finlex) |
| 2 | Corporate income tax return (yhteisön veroilmoitus) Due within four months of the end of the month in which the financial year ends, so 30 April for a 31 December year end. A deadline that falls on a Saturday or public holiday moves to the next working day, as vero.fi states for the company return. There is no standing extension. Verohallinto may extend the time on request (s. 8(3) VML); vero.fi says this is only for special reasons such as illness, and the request must be made before the deadline. Missing financial statements do not excuse a late return; the return can be filed and the statements added later. A late return can bring a late-filing fee or a tax increase. | Day 31 of the 4th month after year end (e.g. Apr 30, 2026) | All companies and other entities with a tax year. Filed electronically in OmaVero (MyTax). | Verohallinto decision VH/5602/00.01.00/2025, s. 11 (in force from 1 Jan 2026) |
| 3 | Country-by-country report (verotuksen maakohtainen raportti) Due within 12 months of the last day of the financial year being reported (s. 14 d(11) VML). It is filed in OmaVero. Late, missing or essentially wrong filing can bring a tax increase of up to EUR 25,000 (s. 32(1) point 3 and s. 32 a(8)). | 12 months after year end (e.g. Dec 31, 2026) | Finnish ultimate parent entity of a group with consolidated revenue of at least EUR 750m in the previous financial year and at least one foreign group party. A Finnish entity of a foreign group files only as a surrogate filer in the cases in s. 14 d(5) to (7). | Verohallinto: Country-by-country report and notification |
| 4 | Top-up tax information return (täydennysveron tietoilmoitus, GloBE Information Return) Due 15 months after the end of the financial year (ch. 8 s. 10). For the first transition year the period is 18 months (ch. 9 s. 3), for example 30 June 2026 for a calendar 2024 year. The law ties the 18 months to the group's own first transition year for Finland, or (since amendment 187/2026) the first year the transitional CbCR safe harbour applies, so a group that first falls in scope later, for example for 2026, also gets 18 months. This tool only applies 18 months to year ends up to 30 December 2025. It is filed in XML in OmaVero. A Finnish entity need not file if the GIR was filed in a country with a qualifying exchange agreement, but must then name the filer. Verohallinto may extend the time on a special request (ch. 8 s. 6(2)); the request must reach it by the due date. A late GIR brings a EUR 5,000 late filing fee (ch. 8 s. 17). A deadline on a weekend or holiday moves to the next working day under s. 5 of the Act on the Calculation of Statutory Time Limits. | 15 months after year end (e.g. Mar 31, 2027) | Groups with annual revenue of at least EUR 750m in at least two of the four preceding financial years that have a group entity located in Finland (s. 2 ch. 1 Minimum Tax Act). | Minimum Tax Act 1308/2023, ch. 8 s. 3, 5, 10 and ch. 9 s. 3 (Finlex) |
| 5 | Notification of the entity that files the GIR (täydennysveron tietoilmoituksen antajaa koskeva ilmoitus) If the GIR is filed in another country under ch. 8 s. 5, the Finnish entity or designated local entity must tell Verohallinto the identity and country of the filing entity. It has the same deadline as the GIR: 15 months, or 18 months for the transition year (ch. 8 s. 10, ch. 9 s. 3). Only a Finnish entity can file it, in OmaVero. A late notification brings a EUR 1,000 late filing fee. | With Top-up tax information return (täydennysveron tietoilmoitus, GloBE Information Return) (e.g. Mar 31, 2027) | Finnish group entities or the designated local entity, when the GIR is filed abroad by the ultimate parent or a designated filing entity. | Minimum Tax Act 1308/2023, ch. 8 s. 5 and 10 (Finlex) |
| 6 | Top-up tax return (täydennysveroilmoitus: IIR, UTPR and domestic top-up tax) One return covers the tax under the income inclusion rule (tuloksilukemissääntö), the undertaxed profits rule (aliverotettujen voittojen sääntö) and the domestic top-up tax. It is due 15 months after the financial year end, or 18 months for the transition year (ch. 8 s. 4 and 10, ch. 9 s. 3). It is an electronic form in OmaVero, and filing for several entities together is not possible. A late return brings a EUR 1,000 late filing fee. Wrong or missing returns can bring a tax increase, usually 10 per cent of the extra tax, 15 to 50 per cent for repeated failures or obvious disregard, and at least EUR 10,000 (EUR 5,000 to 25,000 if no tax was lost) (ch. 8 s. 15 and 16). No tax increase is imposed for years starting by 31 December 2026 and ending by 30 June 2028 if the entity made a careful good faith effort to comply (ch. 10 s. 4). | With Top-up tax information return (täydennysveron tietoilmoitus, GloBE Information Return) (e.g. Mar 31, 2027) | Finnish group entities that must pay top-up tax for the year, whether under the income inclusion rule, the undertaxed profits rule or Finland's domestic top-up tax. Others file only if Verohallinto asks for tax control reasons. | Minimum Tax Act 1308/2023, ch. 8 s. 4 and 10 (Finlex) |
| 7 | Group information in the transfer pricing documentation (master file content) Finland has one transfer pricing document with a group part (master file content, s. 14 b(1) VML) and a taxpayer part (local file content, s. 14 b(2)). It is not filed with the return. It must be handed over within 60 days of a request from the tax authority, and the authority cannot ask for the year's documentation until six months after the end of the month in which the financial year ends (s. 14 c(1)). The group part is not needed if transactions with each related party total EUR 500,000 or less in the year (s. 14 b(5)). It may be in Finnish, Swedish or English. There is no fixed date by which it must be prepared. Verohallinto may extend the time on request (s. 14 c(3)). | Within 60 days of a tax authority request | Finnish taxpayers (companies, partnerships and Finnish permanent establishments of foreign companies) with transactions with foreign related parties, unless they are small or medium-sized enterprises (SMEs). A company is large, and must document, if it has 250 or more employees, or turnover above EUR 50m and balance sheet total above EUR 43m, or fails the independence tests of EU Recommendation 2003/361. Group figures count. The duty starts after the limits are passed in two consecutive years, and ends after two consecutive years below them. If transactions with one related party total EUR 500,000 or less in the year, lighter content rules apply for that party (s. 14 b(5) VML). | s. 14 a to 14 c Act on Assessment Procedure (Finlex) and Verohallinto guidance VH/44/00.01.00/2022 |
| 8 | Taxpayer information in the transfer pricing documentation (local file content) Covers the entity's own organisation, business, related-party transactions, functional analysis, comparability analysis and method (s. 14 b(2) VML). Hand it over within 60 days of the request, and not earlier than six months after the end of the month in which the financial year ends (s. 14 c(1)). For related parties with EUR 500,000 or less of transactions in the year, items 5 to 7 (functional analysis, comparability analysis, method) are not needed (s. 14 b(5)). Not delivering on time, or delivering with essential gaps or errors, can bring a tax increase of up to EUR 25,000 (s. 32 and 32 a VML). | Within 60 days of a tax authority request | Finnish taxpayers (companies, partnerships and Finnish permanent establishments of foreign companies) with transactions with foreign related parties, unless they are small or medium-sized enterprises (SMEs). A company is large, and must document, if it has 250 or more employees, or turnover above EUR 50m and balance sheet total above EUR 43m, or fails the independence tests of EU Recommendation 2003/361. Group figures count. The duty starts after the limits are passed in two consecutive years, and ends after two consecutive years below them. If transactions with one related party total EUR 500,000 or less in the year, lighter content rules apply for that party (s. 14 b(5) VML). | s. 14 a to 14 c Act on Assessment Procedure (Finlex) and Verohallinto guidance VH/44/00.01.00/2022 |
| 9 | Supplementary information to the documentation (for example comparables) Additional information that supports the documentation, such as information on comparables, is due within 90 days of the tax authority's request (s. 14 c(2) VML). The 90 days apply only to the supplement. The first request for the documentation itself gives 60 days. Verohallinto may extend either period on request (s. 14 c(3)). | Within 90 days of a tax authority request | Finnish taxpayers (companies, partnerships and Finnish permanent establishments of foreign companies) with transactions with foreign related parties, unless they are small or medium-sized enterprises (SMEs). A company is large, and must document, if it has 250 or more employees, or turnover above EUR 50m and balance sheet total above EUR 43m, or fails the independence tests of EU Recommendation 2003/361. Group figures count. The duty starts after the limits are passed in two consecutive years, and ends after two consecutive years below them. If transactions with one related party total EUR 500,000 or less in the year, lighter content rules apply for that party (s. 14 b(5) VML). | s. 14 c Act on Assessment Procedure (Finlex) |
| 10 | Payment of top-up tax The Minimum Tax Act has no fixed payment date. The Tax Collection Act covers top-up taxes (s. 1). Verohallinto assesses the tax from the return and sends a tax decision, and the tax is due on the due date entered in that decision (s. 12). The assessment ends on the date in the decision and at the latest two years after the end of the financial year (ch. 8 s. 18 Minimum Tax Act), so the decision normally comes after the 15 or 18 month filing date. If the due date falls on a weekend or holiday, payment on the next working day is on time (s. 74 Tax Collection Act). Check the decision for the date. | See note | Finnish group entities that owe top-up tax for the year (IIR, UTPR or domestic top-up tax). | Tax Collection Act 11/2018, s. 1, 12 and 74 (Finlex) |
| 11 | Notice that a group is in the initial phase of international activity The designated local entity must tell Verohallinto when the group's initial phase of international activity begins (ch. 9 s. 2). The law gives no deadline. During the first five financial years of the initial phase, the top-up tax of the Finnish entities is reduced to zero. Since amendment 187/2026 (in force 31 March 2026) the relief from Finland's domestic top-up tax only applies if the Finnish entity is not held, directly or indirectly, by a parent that applies a qualified income inclusion rule. | See note | Designated local entity of a multinational group that qualifies for the initial phase relief (at most six jurisdictions and at most EUR 50m of tangible assets outside the reference jurisdiction). | Minimum Tax Act 1308/2023, ch. 9 s. 2 (Finlex) |
Official texts
#- Verotusmenettelylaki 1558/1995 (Act on Assessment Procedure), consolidated text, s. 14 a to 14 d, 31, 32 and 32 a (No copyright in laws and regulations (s. 9(1) point 1 Copyright Act 404/1961). Finlex English translations are unofficial; the English here is our own unofficial translation.)
- Laki suurten konsernien vähimmäisverosta 1308/2023 (Minimum Tax Act), consolidated text incl. amendment 187/2026 (No copyright in laws and regulations (s. 9(1) point 1 Copyright Act 404/1961). The English here is our own unofficial translation.)
- Veronkantolaki 11/2018 (Tax Collection Act) and Laki säädettyjen määräaikain laskemisesta 150/1930 (Act on the Calculation of Statutory Time Limits) (No copyright in laws and regulations (s. 9(1) point 1 Copyright Act 404/1961))