Transfer Pricing in Finland

A practical and clear guide for finance and tax teams.

Transfer pricing directly affects a group’s financial steering, risk management and tax predictability. This page brings together the key elements organisations need to manage transfer pricing in Finland.

What is transfer pricing

Transfer pricing defines the terms and prices at which intra‑group goods, services, financing and intangible assets are transferred between companies.

Key areas include:

  • Intra‑group services (administration, IT, finance, HR, marketing)

  • Trade in goods (manufacturing, distribution, contract manufacturing)

  • Intangible assets (licences, royalties, brand, technology)

  • Financing (intercompany loans, guarantees, cash management)

Documentation obligation in Finland

Transfer pricing documentation is a statutory requirement for groups that meet one of the following criteria for two consecutive financial years:

  • more than 250 employees, or

  • both revenue over EUR 50 million and balance sheet total over EUR 43 million

Documentation includes:

  • Master File – group business, value chain, intangibles, financing

  • Local File – the Finnish entity’s role, functions, risks, contracts, comparability analysis

  • Comparability analysis to demonstrate arm’s‑length pricing

  • Agreements and internal calculations

Operational transfer pricing during the financial year

Most transfer pricing risks arise in day‑to‑day operations, not in documentation. Arm’s‑length outcomes must be monitored continuously, especially when the business changes.

Key items to monitor:

  • margins and costs quarterly

  • effects of volumes and exchange rates

  • changes in the scope and content of services

  • changes in the business model

Mid‑year adjustments: If margins deviate from target, pricing can be adjusted during the year.

Mergers, acquisitions and new activities

M&A and new business activities change transfer pricing roles, risks and transactions as they are integrated into the group. Documentation and TP policies must be updated within the same financial year to reflect the new business reality.

Areas to update:

  • TP policy (roles, responsibilities, risks, pricing models)

  • Master File and Local File

  • Comparability analyses and target margins

  • Agreements and service frameworks

  • Operational pricing and cost structure

Contact

Clear, arm’s‑length and risk‑aware transfer pricing supports the group’s overall financial predictability. We are happy to help.