On 7 January 2015, the Finnish government issued a draft proposal to amend the countries transfer pricing rules by adding a new general anti-avoidance clause. The clause would empower the Finnish tax authorities to recharacterize or disregard transactions when the legal form of a transaction does not correspond with its commercial substance.
The proposal is in response to a Finnish Supreme Court decision in 2014, that a transaction may only be recharacterized for transfer pricing purpose whe…