Annual information return on purchases and sales of securities and derivatives, instructions 2025

1 What transactions are reported in the annual information return?

1.1 Sale of securities, redemption of fund units, and purchase of securities

This annual information return is used to report dispositions of securities for consideration (sale, taxable exchange, and purchase). The annual information return may not be submitted on dispositions that do not involve consideration, such as inheritance, donation and distribution of matrimonial assets.

In addition to dispositions for consideration, the reporting obligation also concerns securities (such as warranties) that expire worthless. If the subscription right has been received for free and it is not exercised, i.e. if both the selling price and the purchase price equal 0, the annual information return does not need to be submitted.

Do not report the following transactions as a sale or purchase of securities:

• transfer of securities to the taxpayer’s other book-entry account
• removal of securities from the book-entry system
• exchange of shares for another company’s shares in cases of merger, demerger or share exchange, if § 52 to 52 g of the act on the taxation of business income (Laki elinkeinotulon verottamisesta 360/1968) are applicable to the arrangement.

On this annual information return, you do not need to report

• cash considerations of no more than €100 received in connection with mergers and acquisitions referred to in § 52 to § 52c and § 52 f of the act on the taxation of business income
• cash payments of no more than €100 paid to the shareholder due to the sale of excess shares resulting from a reverse share split under chapter 15, § 9 of the Limited Liability Companies Act.

1.2 Shares given up and shares received in a share exchange

The only situation where purchase/sale codes 3 and 4 (dispositions or receipts of shares in a swap arrangement) are allowed is when the contract actually is a swap within the meaning of the Act on the taxation of business income (under §52f of the Act). The Act’s provision governing swap arrangements is not applicable if either the company whose shares are transferred, or the company that receives shares, is from outside of the European Union and the European Economic Area.

If the arrangement is a swap but the provisions of § 52f of the Act on the taxation of business income do not apply to it, it is an exchange contract involving a transfer of shares subjected to tax, and code 2 (sale) must be used. In this case, the transferred shares’ value for tax purposes is their fair market value at the date when the exchange took place. In addition, if the exchange contract’s opposite party paid any cash or fraction payments to the seller, these must be included in the price.

1.3 Long term savings agreement

This information return is not designed for Finnish-resident taxpayers’ long-term savings agreement-related assets or transactions.

If nonresident taxpayers have purchased or sold securities and derivatives or units in an investment fund, a complete annual information return should be filed as outlined in this instruction including specifications by each beneficiary and all relevant filer Roles, even if the transactions were related to assets within the meaning of the Act governing long-term savings agreements (1183/2009). 

1.4 Equity savings account

This information return is not designed for Finnish-resident taxpayers’ transactions with securities that are related to an equity savings account (under the act governing equity savings accounts). 

If nonresident taxpayers have purchased or sold securities, a complete annual information return should be filed as outlined in this instruction, including specifications by each beneficiary and all relevant filer Roles, even if the transactions were related to assets on an equity savings account.

1.5 Final loss of value in case of bankruptcy

If there are corporate shares in a taxpayer’s book-entry account and the company goes bankrupt so the shares lose their value, it is not treated as a transfer of property that brings about a deductible capital loss for the taxpayer. 

In most cases, the lost value due to the holding of shares in a company that went bankrupt is not, for income tax purposes, considered a final loss until the Trustee in charge of the bankruptcy estate has declared that the estate has no property that could be distributed to the bankrupt company’s shareholders, or until the final balance sheet is prepared for the bankruptcy estate. 

It is not until this stage (a declaration by the Trustee or a balance sheet is made) that the annual information return should contain the capital loss caused by the taxpayer's holding of a bankrupt company’s share.

1.6 Redemption shares of listed companies in Sweden

Listed companies in Sweden can distribute profits through special shares (inlösenaktier) that are designed for buyback by the company, i.e. for redemption. After the company has distributed these shares to its shareholders, the company buys them back at a predetermined date and at a predetermined price. 

In addition, the shares that are distributed this way can be subject to public trading before the predetermined date when the company has agreed to buy them back. The predetermined, agreed redemption price is taxable as dividend income, and the price is also seen as the acquisition cost for the share for tax purposes. The annual information return for transferred foreign dividends (VSULKOSE) must be submitted in order to inform the Tax Administration of the predetermined redemption prices, which are reported in the same way as dividends. 

It is deemed that the shareholder has received the income from a share designed for redemption at the time when the shareholder receives the right to get the share, in accordance with the company’s decision to distribute profits.   If the shareholder sells a share designed for redemption in a public stock exchange, and if the shareholder sells it back to the company i.e. the redemption is carried out, it is treated as a conveyance subject to capital-gains tax. As a result, the gain is calculated by subtracting the amount equated with dividend income from the received selling price – or from the received buyback price. 

The entire amount equated with dividend income is subtracted even if only a part of the dividends were subject to tax.  The annual information return to be submitted when these shares have been sold or redeemed is Annual information return on purchases and sales of securities and derivatives (VSAPUUSE).

2 Who is required to submit an annual information return?

2.1 Reporting requirements of intermediaries in securities (Filer Role 1)

An intermediary in securities transactions referred to in Investment Services Act, foreign service providers and other service providers within the meaning of the Act, an insurance company other than an employment pension institution referred to in Act on Insurance Companies, a representative office and the main agent within the meaning of the Act governing foreign insurance companies, and the agent referred to in the Act governing insurance associations, must deliver information to the Tax Administration. The relevant legal provisions are found in § 15.4, Act on Assessment Procedure, and § 30.1, Act governing transfer tax. The reporting requirement concerns both tax residents and tax nonresidents of Finland. 

The requirement concerns: Purchase/sale of shares, share depository receipts, covered warrants, subscription rights, and units or shares in investment funds and mutual funds (undertakings for collective investment in transferable securities, UCITS). It also concerns derivatives traded in controlled markets, and derivatives referred to in Chapter 1, § 10 b, subsections 3 to 9 of Investment Services Act. In terms of the reporting requirement, it is of no significance whether the traded securities are domestic or foreign. In both cases, transactions traded for own account or for any third party must be reported. 

However, the reporting requirement is not applied to transactions with debt instruments. Sales or purchases of subscription/sell rights should be reported regardless of their amounts. Cash considerations of no more than €100 received in connection with mergers and acquisitions referred to in § 52 to § 52c and § 52 f of the act on the taxation of business income do not need to be reported. Further, cash payments of no more than €100 paid to the shareholder due to the sale of excess shares resulting from a reverse share split under chapter 15, § 9 of the Limited Liability Companies Act do not need to be reported.

Intermediaries in securities should give ‘1’ as the value of position 10, Role of filer (= intermediary in securities transactions within the meaning of Investment Services Act, foreign provider of investment services and other provides referred to in the Act, insurance company within the meaning of the Act on Insurance Companies, a representative office within the meaning of the Act governing foreign insurance companies, and the main agent, and the agent who is referred to in the Act governing insurance associations). 

Those concerned by the information-reporting requirement must deliver it to us and assume Filer Role 1 even if they, or a company of the same consolidated group, also file a report on sales using Filer Role 3. In this way, the same transactions generate two annual information returns (one for Role 1, the other for Role 3). If a disposition (a sale) is being reported using the new Role 4, the same sales transaction cannot be reported twice using Role 1. Nevertheless, it is mandatory to report all purchase transactions using Role 1. 

The above filers (Role 1) are also expected to report the subscriptions/purchases and redemptions of mutual fund (UCITS) shares insofar as the branch in Finland — or the foreign company managing an investment fund established in Finland — has not reported them. For this type of reporting, give ‘2’ as the value of position 10, Role of filer (= fund management company, Finnish branch of a foreign fund management company, or a foreign company managing an investment fund established in Finland). 

You can find more information about the identification of trades and about their reporting in section 5 below.

2.2 Reporting requirements of managements of funds (Filer Role 2)

Fund companies, Finnish branches of foreign fund companies and foreign fund companies that manage an investment fund established in Finland, as well as EEA alternative investment fund managers that manage an alternative investment fund established in Finland must provide information on investment fund, collective investment vehicle and alternative investment fund shares redeemed from taxpayers. The information referred to above must be reported on everyone, both Finnish resident and non-resident taxpayers.  

In this connection, the management should report the purchase prices, purchase dates (acquisition prices and acquisition dates) and the collected subscription and redemption costs relating to any redeemed fund units, provided that this information is available. Actual purchase prices (or tax values in inheritance or gift taxation) should be reported, not the presumed acquisition costs. It is the job of the tax authority to calculate the presumed acquisition costs whenever necessary (in Finnish: hankintameno-olettama; in Swedish: presumtiv anskaffningsutgift). 

In addition, fund management companies, branch offices in Finland or foreign companies managing an investment fund in Finland should notify the tax authority separately of the sum total of the taxable value and quantity of units held by a unit holder-taxpayer in an investment fund, mutual fund or UCITS, and yearly distributions of profits/yield, specifically for each fund, at the end of the calendar year (at 31 December). These facts are reported as shown in the data format specification for Annual information return on interest and other payments, taxable under the provisions of the Act on Income Tax (TVL) (VSTVERIE). Give ‘2’ as the value of position 10, Role of filer (= fund management company, Finnish branch, or a foreign company managing an investment fund established in Finland). To avoid double reporting of fund-unit buybacks or redemptions, the Tax Administration should receive no other annual information report in addition to that submitted as filer Role 2. 

You can find examples for reporting redemptions of fund units in section 6 below.

2.3 Capital gains and capital losses (Filer Role 3)

The reporting requirement on facts and information for the purposes of capital-gains taxation: Credit institutions and branch offices within the meaning of the Act governing the business of credit institutions, investment service companies, including foreign investment service providers within the meaning of Investment Services Act, branch offices and account management companies or custodians within the meaning of the Act governing the book-entry securities system and its clearance operations, must give us information as outlined in this instruction and specification. 

The reporting requirement concerns the selling of securities by natural persons and estates of deceased persons, both tax resident and tax nonresident in Finland. This information-reporting requirement is not intended as a limitation of any other information-reporting requirement of banks, investment service companies and other providers (Filer Role 1), such as the requirement to report the transactions in securities that they have brokered or carried out. 

The requirement concerns: sales of shares, share depository receipts, covered warrants, subscription rights, and units or shares in investment funds and mutual funds (undertakings for collective investment in transferable securities, UCITS). It also concerns derivatives traded in controlled markets and derivatives referred to in Chapter 1, § 10, subsection 1:3-9 of Investment Services Act. In terms of the reporting requirement, it is of no significance whether the traded securities are domestic or foreign. In both cases, you must report the sales. However, the reporting requirement is not applied on sales of investment-fund shares or UCITS units, insofar as the fund management company delivers the relevant information pursuant to § 17.1 of Act on Assessment Procedure. Sales of debt instruments such as bonds are reportable with filer Role 4 (not Role 3). Sales or purchases of subscription/sell rights should be reported regardless of their amounts. Cash considerations of no more than €100 received in connection with mergers and acquisitions referred to in § 52 to § 52c and § 52 f of the act on the taxation of business income do not need to be reported. Further, cash payments of no more than €100 paid to the shareholder due to the sale of excess shares resulting from a reverse share split under chapter 15, § 9 of the Limited Liability Companies Act do not need to be reported. 

Report the selling price, selling date, costs collected for the sale, and the reference that identifies the sale (Infinity or some other Reference) and also the Transaction Code. The Transaction Code is the filer’s unique identifier of the transaction that facilitates differentiation between transactions closed on the same day, representing the same type, and having the same quantity. When you use both Role 1 and Role 3 to report the same sales transaction, you must use the same Reference in both reports. As a filer, you also must report the purchase price, purchase date and the costs relating to the purchase. If any type of corporate action, such as a split or a bonus issue have had an impact on the purchase price, or if the origin of the purchase-price information is the taxpayer himself, please report this as well. You must report the actual purchase prices (or tax values in inheritance or gift taxation), not the presumed acquisition costs. It is the job of the tax authority to calculate the presumed acquisition costs whenever necessary (in Finnish: hankintameno-olettama; in Swedish: presumtiv anskaffningsutgift). 

As a filer fulfilling your information-reporting requirement, you must submit the facts and information about purchases and sales insofar as you have them in your possession. If you do not have all the necessary information for completing the capital-gains-tax computation in full (e.g. you do not know the historical purchase price of the security that has now been sold), however, you must submit any and all information that you have. 

If your role as a filer has only consisted of being an account operator or custodian and the selling price is not known because of your limited responsibility, then Role 3 is in question, and there is no requirement to hand in an annual information return.

You can find more information about the identification of trades and about their reporting in section 5 below.

2.4 Reporting requirements for filer Role 4

2.4.1 Bonds, peer-to-peer loans and crowdfunded loans

Filers must additionally include sales and other transfers of bonds (issued debt instruments) when reporting the facts necessary for computing the taxpayer's taxable amounts of capital gains, and similarly, deductible loss.  The facts should be submitted fully to the extent that they are saved in such a format that permits information-reporting. Filers are expected to report sales of bonds even if they do not quite have all the necessary information for capital gains/capital losses calculation (e.g. no acquisition price information). 

This information-reporting requirement concerns all bonds including interest-bearing bonds and index-linked bonds. Filers should use Filer Role 4. Sales and other dispositions of bonds are not reportable using the brokerage Role 1, intended for brokers/intermediaries of securities. Similarly, Role 3 is not suitable for the reporting of bonds sales. 

Only filer role 4 can give information about payment types 45 = peer-to-peer loan and 46 = crowdfunded loan, and purchase/sale code 2 = sale must then be used. The “quantity” of payment types 45 and 46 is the loan capital.

2.4.2 Redemption of minority shares

According to Chapter 18 of the Companies Act, a shareholder with more than 90% of all the shares in the company has the right to redeem the shares of the other shareholders. In the case of such redemption of minority shares, the securities custodian must file an annual information return on securities trading (VSAPUUSE) using filer role 4, in order that the information could be processed for purposes of tax assessment without the intermediary’s (filer role 1) reports.

The sale of a share (redemption price) is reported for the year when the ownership of the share has transferred to the buyer.The date of payment is here irrelevant. If the redemption right has been legally resolved or arbitrators regard it as undisputed but the redemption price has not been agreed or determined, the share transfers to the redeemer immediately after the redeemer has given a guarantee for payment and the arbitrators have accepted it. If the redemption price has not been agreed or determined before the annual information return must be submitted, the offered price is reported as the redemption price.  The date of payment is here irrelevant. If the redemption right has been legally resolved or arbitrators regard it as undisputed but the redemption price has not been agreed or determined, the share transfers to the redeemer immediately after the redeemer has given a guarantee for payment and the arbitrators have accepted it. If the redemption price has not been agreed or determined before the annual information return must be submitted, the offered price is reported as the redemption price.

2.4.3 Filer role 4 as an alternative to filer role 3

Filer role 4 can be used instead of role 3 in situations where the filer has fully ensured, to avoid double reporting, that the sales transaction will not be reported by any intermediary with role 1

Role 4 enables filers to submit only one filing to report sales transactions. The purpose of Role 4 is to facilitate calculation of capital gains and capital losses, because the filers can report the necessary information more simply. 

Sales transactions reported using Role 4 should not be doubly covered by reporting them using Role 1 or Role 3. Intermediaries of securities (using Role 1) continue to have the full information-reporting requirement regarding all purchases of securities. 

Use of Role 4 is only allowed in cases where the filer has been able to make sure that the sales transaction in question will not be doubly reported by an intermediary using Role 1. If the filer is unable to make sure of this, he must complete his filing using Role 3 as previously. The annual information regarding a single sales transaction can be submitted either using Role 3 or Role 4, but not both. 

Use of Role 4 is based on a voluntary choice. This means that the filer can continue, as in previous reporting years, to use Role 3 to submit annual information on sales transactions. If Role 3 is used, the same transactions should also be reported using Role 1, as previously. In this way, the introduction of Role 4 does not absolutely require that existing report-generation systems be changed, if filers do not wish to make any changes. 

Use of Role 4 to report sales transactions is wholly permitted even if the filer does not quite have all the necessary information for capital gains/capital losses calculation (e.g. no acquisition price information).

You can find more information about the identification of trades and about their reporting in section 5 below.

3 When to file the return?

The annual information return must be submitted by 31 January of the year following the year of trading. If the deadline falls on a Saturday, Sunday or other holiday, it is extended to the next business day, i.e. the submitted return must arrive at the Tax Administration on that day.

4 Detailed instructions

4.1 Reporting monetary values

If transaction currency is entered as a foreign currency and the currency of payment was a non-euro currency, you must convert it into € using the ECB rate valid at the date of payment.

4.2 Quantity of units sold/purchased/redeemed

Use 6 decimals. 

For example, for the quantity of 1500 units, write 1500,000000 and for 0.765 units, write 0,765000. 

In the case of bonds (filer role 4, security type codes 07 or 57) give the nominal value of the loan at the date of issue in an unspecified currency. Thus, for GBP 9,999, write 9999,000000.

4.3 Security type codes

For reporting purposes, foreign securities have different codes than Finnish securities. Report the transactions at the Helsinki Stock Exchange as Finnish, other transactions as foreign. 

Permissible values: 

Finnish securities: 

01 = shares

02 = subscription rights for a new issue 

03 = subscription rights for a bonus issue 

04 = other derivative contracts 

05 = fund units of an investment fund 

06 = special subscription rights, listed options  (including stock options related to an employment contract) 

07 = bonds 

08 = covered warrants 

09 = index shares (ETF) 

11 = domestic sales rights 

41 = call options 

42 = put options 

43 = term contracts 

44 = future contracts

45 = peer-to-peer loan

46 = crowdfunded loan 

Foreign securities:

51 = shares 

52 = subscription rights for a new issue 

53 = subscription rights for a bonus issue 

54 = other derivative contracts 

55 = shares of a UCITS 

56 = special subscription rights, listed option 

        (including stock options related to an employment contract) 

57 = bonds 

58 = covered warrants 

59 = shares of a UCITS (e.g. index share) 

61 = foreign sales rights 

81 = call options 

82 = put options 

83 = term contracts 

84 = future contracts 

99 = foreign securities, no exact description or details available. 

For Roles 1 and 3, all of the above values (except 07, 57, 45 and 46) are permitted. For Role 4, all of the above values are permitted. For Role 2, values 05 and 55 only are permitted. Note that 07, 57, 45 and 46 are permitted for Role 4 only. 

Use codes 41 to 44 to report Finnish derivative contracts traded in controlled markets. Report call and put options separately as follows: call options (code 41), put options (code 42). Similarly, use codes 81 to 84 to report foreign derivatives. 

Use code 05 for Finnish fund units/shares, and code 55 for comparable shares of foreign undertakings for collective investment (UCITS). Enter the name of the fund under ”Name of security” and the business ID (if any) of the management company under ”Business ID of Management Company”. Enter the business ID under "Intermediary's personal identity code / Business ID". 

Finnish index-linked fund shares (ETF, Exchange Traded Fund) are reported with the specific code 09, and correspondingly, comparable shares of exchange traded funds / UCITS from other countries (e.g. foreign index share) with code 59. 

The time when a sale is reportable (084=2) for index-linked future contracts with daily clearance and settlement (by variation margin) is at the date of closure of the position or at the contract’s date of expiration. If this type of futures were traded, populate the Date of sale (124) as the date when the position closed or the contract expired, and Transaction price (149) = the total of client-received net settlements, and enter the client-paid total net settlements as the Subscription or Purchase price (161). 

A Share Depository Receipt (FDR) issued for trading in the Finnish book-entry system is comparable with a Finnish basic share. 

The primary means of reporting any security from another country is under the descriptive code relating to the type of security. Do not use code 99 except if you do not know the type of security.

Use the type of security “01” (shares) to indicate selling and other transfers of a cooperative society’s share.

4.4 Buyer’s or seller’s address details

If the personal identity code or Business ID reported for the client is artificial, submit address details. In the first place, report the address details as they were on the date of transaction (for example, in a sales itemisation, address details on the selling day). Do not enter address details that are covered by a non-disclosure order for personal safety reasons.

4.5 Country codes

For all country codes of the ISO 3166 standard, see List of country codes. 

4.6 Purchase price of securities is known / is not known

4.7 Purchase price and date are client-supplied

Value 1 refers to situations where the taxpayer himself has written the purchase price and date information in the service company’s software system or to situations where the service company has relied on taxpayer-supplied information without confirming these facts from documents. 

Value 2 refers to situations where the service company, not the taxpayer, has been responsible for data input regarding purchase. You can also use value 2 (price information not client-supplied) when sufficient checks based on documentation have been made to confirm the purchase information originally written by the taxpayer. 

Value 3 above to situations where there is no knowledge as to the origin of the purchase information, or similarly, no knowledge as to whether documentation has been used for confirming the purchase prices and dates.

4.8 Reference

Both Role 1 and Role 3 must include a Reference in pos. 350-384 to show each sale as a separate, identifiable transaction. Tax Administration will use the Reference for making sure that tax only is collected once on one sale, taking account of the information returns received from both Role 1 and Role 3. 

For Reference, you must enter an Infinity Matching or other reference. For Role 4, the Reference is not required. 

Sales, reported per transactions, that include an Infinity (having taken place at Helsinki Stock Exchange), must simply be identified using the Infinity as the Reference, provided that the filer knows it. Sales that do not have an Infinity at all (foreign or other sales outside of the Infinity reference framework) or sales that do have an Infinity but the filer does not know it, may include some other Reference in the reporting. Other reference is any other 35-character string (alphanumeric, max. 35 chars) that filers can utilize and include in their return.   

Sales reported by each brokerage request must be identified by other Reference.

Both Role 1 and Role 3 must use the same Reference to identify the same sale (one of the following two alternatives: the same Infinity or the same Other Reference), if it is known to the filer of either Role what the other Role is using (this situation would occur when an Intermediary Company (Role 1) and an Investment-Service Company/Custodian (Role 3) belong to the same consolidated group of companies). 

In situations where Role 3 is expected to report the sales separately for each acquired batch of securities, Role 3 must use the same reference (the same Infinity or the same other reference) to identify all sales of the batches, and correspondingly, Role 1 must use the same reference as Role 3 is using.

4.9 Additional information

If the personal Identity Code/Business ID of the buyer/seller/redeemer is not known, this field is for any other particulars (such as Name, Address, Country code) that have not been submitted earlier. 

The entries in the “Additional information” are forwarded to the Tax Administration’s reception of annual information returns; however, they are not used for purposes of tax assessment. The field is intended for all Filer Roles: 1, 2, 3 and 4. 

4.10 Transaction code

The Transaction Code is the filer’s unique identifier of the transaction that facilitates differentiation between transactions closed on the same day, representing the same type, and having the same quantity.

The same annual information return may not contain two or more itemisations with identical identifying details. If you submit such a file, the itemisations with identical details for identification would be replaced, and only one of them would remain in force. If the identifying details of some itemisations are similar in all other respects, you can prevent unwanted replacement by giving the itemisations different transaction codes. Transaction code can be any string of alphanumeric characters that you create for this purpose. 

4.11 Transfer tax 

The annual information return no longer contains a specific field for transfer taxes. If the buyer of securities paid transfer tax upon purchase, the transfer tax can be included in the acquisition expenses of the shares and entered in the appropriate field. If in connection with purchases and sales of securities, any taxes known as “financial-market tax” were paid to foreign countries, you can also include them in the acquisition or selling expenses and enter them in the appropriate fields. 

5 Examples of reporting and differentiation (Filer Role 1, 3 or 4)

5.1 Selling securities

It is not permissible that a single trading transaction result in more than one annual information return from the same filer Role, when this transaction is consummated by one taxpayer (one taxpayer being either the seller or the buyer). Example: Two intermediary companies participate in a trading transaction so that the taxpayer’s Investment-Service Company engages the services of a Stock-Exchange Broker to sell a security. This cannot result in more than one annual information return from Role 1, and this return should show the taxpayer (the end client) as the seller. However, the Stock-Exchange Broker can in the above situation hand in an annual information return for the sale of the security, showing the Investment-Service Company as the seller, selling the security for the account of the client. 

Role 1, Role 3 and Role 4 can report sales transactions of securities separately for each transaction. As an alternative to that, Role 1, Role 3 and Role 4 can report sales transactions of same type securities, based on the same client request, separately for each brokerage request as ordered by client with the restriction that each date should be shown separately, so that if one client request is being fulfilled during several consecutive days or dates, the relevant transactions should be reported separately for each date. The same Role must not report the same sale twice (for each transaction, and simultaneously, for each brokerage request), but sales of different securities can be reported in two different ways (for each transaction, or alternatively, for each brokerage request). 

Filers representing Role 1 and Role 3 should coordinate their filings in order to report the same sale in the same way (for each transaction, or alternatively, for each brokerage request), if the filers are aware of each other’s reporting (this situation would occur when an Intermediary Company (Role 1) and an Investment-Service Company/Custodian (Role 3) belong to the same consolidated group of companies). 

If sales transactions have been reported using Role 4, the same sales transactions should not be reported doubly in any annual information return using Role 1 or Role 3. 

5.2 Purchasing securities

Role 1 can report purchases separately for each transaction, or separately for each request. With the latter alternative it is always required that all the day’s finalized transactions must be reported date-for-date. Regarding purchases, use of Infinity or other reference is permissible but not mandatory. 

Roles 2, 3 and 4 are not expected to file an annual information return regarding purchases. 

6 Examples of how to report buyback transactions (Filer Role 2)