Finland has implemented Country-by-Country Reporting (CbCR) requirements in accordance with the OECD/G20 BEPS Action 13 initiative. These obligations are aimed at promoting tax transparency and ensuring profits are taxed where economic activities occur. This guide provides a detailed overview for multinational enterprises (MNEs) with operations or headquarters in Finland.
Regulatory Framework
- Authority: Finnish Tax Administration (Verohallinto)
- Legislation:
- Act on the Disclosure and Exchange of Information on Tax Matters (448/2017)
- Government Decree on the Country-by-Country Report (464/2017)
- Finnish Tax Administration Guidelines on CbCR
- International Engagement:
- Finland is a member of the OECD and a signatory to the Multilateral Competent Authority Agreement (MCAA)
CbCR Filing Requirements
- Who Must File:
- MNE groups with consolidated revenue of EUR 750 million or more in the previous fiscal year
- The ultimate parent entity (UPE) resident in Finland is required to file the CbC report
- A Finnish subsidiary may also be required to file under secondary filing rules
- CbCR Notification:
- Finnish entities must notify the Tax Administration of the reporting entity and the country of filing
- Notification deadline: annually by the end of the financial year
- CbCR Submission:
- Must be submitted within 12 months of the end of the reporting fiscal year
- Submitted electronically via the Finnish Tax Administration’s reporting system in XML format (OECD schema)
Penalties for Non-Compliance
- Failure to file or submit inaccurate/incomplete information:
- Administrative fines of up to EUR 15,000 may be imposed
- Additional consequences include risk-based audits and assessments
Important Considerations
- CbCR data is exchanged automatically with partner jurisdictions under the MCAA
- Data must be consistent with Master File, Local File, and other transfer pricing documentation
- Finland applies OECD guidance strictly and expects full alignment with international standards
Useful Resources
- Finnish Tax Administration (CbCR page): https://www.vero.fi/en/businesses-and-corporations/about-corporate-taxes/international-tax-situations/country-by-country-reporting/
- OECD CbCR Portal: https://www.oecd.org/tax/beps/country-by-country-reporting.htm
CbC Reporting 
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