Transfer pricing documentation

Transfer pricing documentation is a written statement prepared by the taxpayer on how transactions between the company and its affiliates have been handled. Intra-group transactions must follow the principle of market conditions, i.e., the price and terms of the business should be the same as with an external partner.

Transfer pricing documentation is divided into two phases. The company must provide country-specific information, annually, in connection with the tax return, with Form 78. The actual transfer pricing documentation should be provided to the taxpayer, upon request.

Companies that meet at least one of the following requirements are required to document:

  • the company employs at least 250 people
  • the company has a turnover of more than 50 million euros and a balance sheet total of more than 43 million euros
  • The company does not meet the characteristics of a small and medium-sized enterprise (according to Council Recommendation 2003/361/EC).


When assessing the key figures of an individual taxpayer in accordance with the Council’s recommendation, in practice, the figures in the consolidated financial statements of the group’s highest parent company are examined. The figures of companies in which the company has a 25-50 percent holding or control may also be added to these figures.

The obligation to document minor related controlled transactions has been relaxed. Minor related controlled transactions refer to actions with a maximum contact amount of EUR 500,000 in a tax year. This is required for transactions between the taxable person and each business partner; none of them may exceed EUR 500 000.

The obligation to document also applies to transactions between a foreign company and its permanent establishment in Finland. The documentation must be done in the same way as a separate company would prepare it, in a similar situation.

Our experts

Tuokko-Meri-Väinölä

Meri Väinölä

Head of Accounting & Outsourcing Services, APA (HT), Partner

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Tuokko-Noora-Nikkilä

Noora Nikkilä

Team Manager
Accounting & Payroll

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