Finland’s Government Decree 464/2017 implements the requirements for Country-by-Country (CbC) reporting as part of its commitment to the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 and the EU Directive 2016/881/EU. The decree mandates large multinational enterprise (MNE) groups to provide detailed annual reports on their global operations, aimed at increasing tax transparency and combating tax avoidance.

Key Provisions

Scope and Applicability

• The CbC reporting obligation applies to multinational enterprise groups with total consolidated group revenue of at least €750 million in the preceding financial year.
• The reporting requirement covers financial years beginning on or after January 1, 2016, with the decree effective from January 1, 2017.

Reporting Requirements

• The ultimate parent entity of the MNE group resident in Finland, or another designated reporting entity, must file the CbC report with the Finnish tax authorities.
• The report must be submitted within 12 months of the last day of the reporting fiscal year.
• The CbC report must follow the standard OECD template, which includes information for each tax jurisdiction where the group operates, such as:
  • Revenue
  • Profit (loss) before income tax
  • Income tax paid and accrued
  • Number of employees
  • Stated capital
  • Retained earnings
  • Tangible assets

Exchange of Information

• Once submitted, the Finnish tax authority automatically exchanges the CbC report with tax authorities in other countries where the group has operations, in accordance with EU and OECD standards.

Documentation

• In addition to the CbC report, Finland’s transfer pricing documentation rules require the submission of a master file and a local file, as per BEPS Action 13 guidelines.

Penalties

• Non-compliance with CbC reporting requirements can result in significant administrative penalties.

Summary Table

Requirement	Details
Threshold	€750 million consolidated group revenue
First Reporting Year	Financial years starting on or after January 1, 2016
Filing Deadline	Within 12 months after the end of the reporting fiscal year
Report Contents	Revenue, profit, tax paid/accrued, employees, capital, assets, etc.
Submission Format	OECD standard template (XML format)
Exchange of Information	Automatic with relevant tax authorities
Public Disclosure	Not required
Additional Documentation	Master file and local file
Penalties for Non-Compliance	Administrative penalties