FINLAND Law and Practice Contributed by: Petteri Rapo, Markku Renko, Henri Becker and Jaakko Niskala, Svalner Atlas Finland
5.4 Reporting Obligations and Disclosure Regimes Finland uses extensive reporting and disclosure regimes to detect and prevent tax fraud, evasion and avoidance, especially in cross‑border situations. Key regimes include: • DAC6 (reportable cross-border arrangements): Intermediaries (service providers) or, in some cases, the relevant taxpayer must report qualify - ing cross-border arrangements that meet specified hallmarks. Reports must generally be filed within 30 days from the triggering event, and can be submitted via MyTax or Ilmoitin.fi (including XML/ name-value formats). • Country-by-country (CbC) reporting: Multinational groups meeting the threshold (generally EUR750 million consolidated revenue) are subject to CbC reporting and notification obligations. The Finnish Tax Administration provides detailed instructions and e-filing processes for both the CbC report and the notification of reporting entity. • Transfer pricing documentation and annual dis- closure: Taxpayers within scope must maintain transfer pricing documentation and submit annual disclosures (including Form 78 “Explanation of Transfer Prices” with the corporate income tax return where applicable), supporting risk assess - ment and audit selection. • Automatic exchange of information (AEOI) – FAT- CA/CRS/DAC2: Finnish financial institutions must identify reportable account holders and file annual information returns. Finland then exchanges such information automatically with partner jurisdictions, which “enhances tax control and combats tax eva - sion”. • Other third-party reporting regimes: Finland also applies structured third-party reporting frameworks (eg, platform operator reporting and other speci - fied reporting duties) within the Act on Assessment Procedure framework. The Tax Administration has detailed guidance on penalty payments relating to failures to comply with specified third-party report - ing obligations (including FATCA/CRS/DAC2, DAC6 and platform reporting).
venting the diversion of Finnish-taxable income to low-taxed foreign entities; (ii) interest limitation rules (EVL 18 a/18 b) restricting net interest deductions to address base erosion through excessive debt fund - ing; and (iii) transfer pricing rules based on the arm’s length principle, including documentation obligations and reporting (eg, Form 78, CbC rules), used both for compliance and as a basis for audit selection and potential adjustments. Finland also relies heavily on transparency and disclo - sure. DAC6 requires reporting of certain cross-border arrangements that meet hallmarks associated with aggressive tax planning, thereby enabling early detec - tion and deterrence. In addition, Finland participates in automatic exchange of financial account information (FATCA, CRS and DAC2), which strengthens tax con - trol and combats offshore evasion. Finally, Finland has implemented enhanced procedures in the withholding tax context (eg, for nominee-registered shares) that require identifying and verifying the dividend benefi - ciary before treaty benefits can be granted at source. 5.3 Blacklists and Non-Cooperative Jurisdictions Finland does not rely on a stand‑alone domestic “blacklist” in the same way some jurisdictions do; however, for EU purposes, Finland references the EU list of non‑cooperative jurisdictions for tax pur - poses in areas such as DAC6 reporting. The Finnish Tax Administration explicitly notes that updates to the EU list should be taken into account when reporting arrangements under the DAC6 hallmark that refers to non‑cooperative jurisdictions. Tax consequences in Finland that are clearly linked to “listed jurisdictions” are therefore most directly seen through reporting/monitoring effects (eg, DAC6 hall - mark-driven reporting and increased transparency), rather than an automatic, Finland‑specific punitive tax rate solely triggered by a blacklist designation. Where cross-border payments are concerned, Finland’s sys - tem can also impose practical consequences where beneficiary identification is not properly established for treaty relief at source, requiring robust verification and documentation.
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