Scope and Thresholds

• CbCR applies to multinational enterprise (MNE) groups with consolidated turnover of at least €750 million in the preceding fiscal year. If the consolidated accounts are in a currency other than euro, the threshold is assessed using the equivalent of €750 million based on the January 2015 exchange rate or as set by the parent entity’s jurisdiction.
• The obligation exists for financial years starting on or after January 1, 2016.

Reporting Obligations

• The ultimate parent entity resident in Finland must submit the CbC report to the Finnish Tax Administration within 12 months from the end of the relevant accounting period.
• If the ultimate parent is not resident in Finland, a Finnish group company must file the CbC report if:
  • The foreign parent is not subject to CbCR in its jurisdiction,
  • The parent is in a jurisdiction with no CbCR exchange agreement with Finland,
  • Or the parent is in a jurisdiction that has systematically failed to exchange CbC reports, as identified by Finnish authorities3.
• If a surrogate parent entity is appointed (either within the EU or, under certain conditions, outside the EU), it may fulfill the reporting obligation.
• All Finnish group companies and permanent establishments must submit a notification to the Finnish Tax Administration by the last day of the fiscal year, indicating which entity will file the CbC report.

Report Content and Format

• The CbC report must include, for each tax jurisdiction:
  • Revenues,
  • Profit or loss before tax,
  • Income tax paid and accrued,
  • Withholding tax,
  • Book value of equity,
  • Accumulated earnings,
  • Number of employees,
  • Tangible assets (excluding cash and equivalents).
• The report should also describe the business activities of each group entity, data sources, and the currency used.
• Reports and notifications can be filed in Finnish, Swedish, or English.
• The report must be submitted electronically, either in XML or CSV format, using the Finnish Tax Administration’s online platform.

Deadlines

Obligation	Deadline
CbC Report submission	12 months after the end of the accounting period
Notification of reporting entity	By the last day of the fiscal year covered by the report

Enforcement and Penalties

• Penalties may be imposed for non-compliance with CbCR requirements, but there is no imprisonment or shifting of the burden of proof as a consequence.

Consistency with OECD Standards

• Finnish CbCR rules are consistent with OECD guidelines and the EU Directive, and Finland is a signatory to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports.

Recent Developments

• Amendments in December 2024 introduced additional transitional safe harbour rules for CbCR, aligning with the latest OECD administrative guidance. These include provisions for purchase accounting adjustments, joint ventures, use of different accounting standards, and treatment of hybrid arrangements.

Submission Process

• Submission is via the Finnish Tax Administration’s electronic filing platform. A KATSO-ID (electronic identification) is required for access.

Summary Table

Requirement	Details
Threshold	€750 million consolidated turnover
Reporting Entity	Ultimate parent (or surrogate) if resident in Finland
Notification	By end of fiscal year, via electronic platform
Report Deadline	12 months after fiscal year-end
Languages	Finnish, Swedish, English
Format	XML or CSV
Content	Revenues, profits, tax, employees, assets, business activity
Penalties	Yes (no imprisonment)
Consistency	OECD-aligned