Country-by-country reporting
Country-by-country reporting applies to multinational group companies with a consolidated turnover/net sales of at least €750 million.
- If the consolidated financial statements are prepared in a currency other than the euro, the threshold is considered to be the limit set in the legislation of the state of domicile of the group company's ultimate parent entity, roughly equivalent to €750 million, based on the currency exchange rate in January 2015.
- If the Ultimate Parent Entity's state of domicile does not have legislation on CbC reporting, you should convert that state's local currency into euros by the exchange rate that was in force in January 2015 to determine whether the €750 million threshold is reached.
Example: Under The United States legislation, the reporting obligation applies to multinational enterprise groups with a turnover/net sales of at least $850 million.
Country-by-country reporting involves two separate reports
- The Notification of Reporting Obligation – applies to all group companies and permanent establishments in Finland if the permanent establishment's accounting contains specific financial statements for purposes of general financial reporting, in compliance with legal statutes, for tax reporting or for internal control
- The CbC Report – applies to the Finnish group company's ultimate parent entity
Guidance: Country-by-country report
File the report online
To submit a notification of reporting entity or a country-by-country report, you will need a personal User ID and password.
If an agent submits the reports, they must have authorisation for Suomi.fi, the "Managing of tax affairs" or "Tax return filing". The notification opens with the login page. When you have logged in, you will automatically be routed to the correct form.
Giving details of the Reporting Entity
The obligation to file a Notification of the Reporting Entity applies to companies that are resident taxpayers in Finland and to permanent establishments located in Finland when they belong to a group whose consolidated net sales amount to at least €750 million in the accounting period preceding the reported period. The obligation concerns a permanent establishment if separate financial statements are prepared for it for the purposes of financial reporting, regulation, filing of taxes, or control of internal management.
You can file the notification in MyTax.
To submit the notification as a computer file, create a name-value file and send it on Ilmoitin.fi. Specifications of the required data format (select the correct year) are under Notification of the Reporting Entity (CbC and DAC4).
How to submit the CbC Report
You can file the report in MyTax.
You can send us an XML file via Ilmoitin.fi.
On the Annual Information Returns page, under Country-by-country report (CbC and DAC4), you find the
- Technical guidance (pdf)
- Models and examples of xml files
Country-by-country report
The group company's ultimate parent entity is usually responsible for submitting the CbC Report to the tax authority of its state of domicile within 12 months from the end of the accounting period. If you are the ultimate parent entity, and Finland is your state of domicile, you must file the reports to the Finnish Tax Administration. In case an agreement on exchange of information is in force between Finland and the state of domicile, the ultimate parent entity of a foreign multinational enterprise group files the CbC Report to the tax authority of its state of domicile, and that tax authority will transmit it to the Finnish Tax Administration automatically.
Example: The tax residence of your group's ultimate parent entity is Sweden. The group has a subsidiary in Finland.
The Swedish parent entity must submit its country-by-country report to the Swedish Tax Agency which in turn will send it on to the Finnish Tax Administration. The Finnish subsidiary does not need to compile a separate report, as the Swedish parent entity compiles it on the subsidiary’s behalf.
Consequently, the subsidiary and permanent establishment in Finland must ascertain whether the ultimate parent entity must file country-by-country reports in its state of domicile, and also ascertain whether an agreement is in force on exchange of information between Finland and the state of domicile. If the ultimate parent entity does not submit a report in its state of domicile, or if no agreement on information exchange is in force, the Finnish subsidiary must ascertain whether the parent entity has designated one of the group companies to submit reports on its behalf. This company is referred to as a "surrogate parent entity".
Exceptions
Finnish group companies and permanent establishments located in Finland are obligated submit country-by-country reports to the Finnish Tax Administration only in exceptional situations.
More information on constituent entities is available in the detailed guidance on country-by-country reporting in Finnish. The term secondary constituent entity is used in Tax Admnistration documents to refer to an exceptional reporting obligation such as this.
If the situation is unclear, we recommend that you first contact your Ultimate Parent Entity in the country where it is located to ascertain which group company must file the reports. You can also contact the Tax Administration by e-mail: siirtohinnoittelu(a)vero.fi
Description of the international exchange of tax information
The OECD has a list on the active agreements on information exchange that apply to CbC Reports and related exchange of information.
OECD's list of information exchange agreements
How to use the OECD website to find a list of countries that send information to Finland:
- Go to "From jurisdiction" menu and "Select All".
- Select "Finland" as the "To jurisdiction".
How to find a list of the countries that receive information from Finland:
- Go to "From jurisdiction" menu and "Finland".
- Go to "To jurisdiction" and "Select All".
Further information:
Country-by-Country report and notification — other pages
Key terms: