Finland's Ministry of Finance on 21 December 2015 issued draft legislation that includes revisions to the country's transfer pricing documentation rules to require Country-by-Country (CbC) reports. The proposed revisions are based on the guidelines developed as part of Action 13 of the OECD BEPS Project, including Master File, Local File and CbC report requirements.
The CbC reporting requirements would apply for ultimate parent entities of MNE groups resident in Finland where the annual cons…