Résolution des différends

Finland Dispute Resolution Country Profile



last update 30 January 2013

Competent Authority

Finnish Tax Administration
FI-0052 VERO


MAPs are generally handled by the Finnish Tax Administration. Another Competent Authority is the Ministry of Finance. The Standing Orders of the Tax Administration contain more detailed norms on division of tasks between different units. Three units are involved with the mutual agreement procedure.

The Finnish Tax Administration can provide more detailed information on who to contact.

Scope of MAP & MAP APA

Majority of work involves transfer pricing (includes MAP and APA requests). Also other application or interpretation of a particular tax treaty.

Domestic guidelines & administrative arrangements

Guidelines in English:

Foreign tax assessment not in line with the terms of the tax treaty (http://www.vero.fi/en-US/Precise_information/International_tax_situations/Foreign_tax_assessment_not_in_line_with_(14386))

Time for filing

N/A (see specific tax treaty).

Form of request

No specific form required (see English guideline above).

Documentation requirement

No formal requirement.

User fees


Tax collection / penalty / interest

Under article 90 of AAP, a regional tax office is entitled, on special grounds, to admit deferment to tax collection.

Other dispute resolution mechanisms

The EU Arbitration Convention for the transfer pricing cases.

Government Website 





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