Transfer pricing


Transfer pricing

Tax services

Deloitte offers clients a broad range of fully integrated tax services. Our approach combines insight and innovation from multiple disciplines with business and industry knowledge to help your company excel globally.

Transfer pricing

Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of Deloitte’s transfer pricing network is to help companies manage risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results.

Transfer pricing advisory and documentation

Multinational businesses are expanding the volume of related-party transactions and continuously improving their supply chains. This coupled with increased tax authority collaboration across borders presents both risks and opportunities.

Like many other countries globally, Finland has adopted transfer pricing documentation rules, effective as of the financial year 2007. As a result, many Finnish based multinational companies have faced a need to prepare transfer pricing documentation. Furthermore, the Finnish Large Taxpayer’s Office has also concentrated heavily on transfer pricing matters during recent years. Considering this, the focus on transfer pricing is increasingly important to Finnish based multinational companies. Deloitte Finland provides practical solutions such as strategic approaches to transfer pricing documentation requirements, which help global businesses to achieve their operational and international tax objectives as well as to comply with the local transfer pricing requirements.

Dispute avoidance: Advance pricing agreements (APA)

Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties – including the potential commitment of significant management time in the event of a transfer pricing examination – is not an acceptable business risk. Advance pricing agreements (APAs) allow taxpayers to achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities.

Although as of yet there is no formal APA process in Finland, there are several ways to achieve a similar outcome: the possibility to apply for a Finnish advance ruling as well as tax treaty provisions make it possible to find an agreement with the Finnish and foreign tax authorities on transfer pricing of multinational companies.

Deloitte Finland's knowledge and insight of such processes combined with practical experience and the support of our extensive global network help us to assist companies in managing their transfer pricing issues – particularly the risk of double taxation – on a prospective basis.

Dispute resolution: Examination defense and mutual agreement procedure (MAP)/competent authority

The initial stages of tax authority enquiries or interviews affect the course or outcome of a transfer pricing examination. Accordingly effective and efficient explanation of transfer pricing policies include early involvement of an experienced local team that has practical experience of all levels of the tax authority process, from proposed adjustments, through Advance Pricing Agreements, administrative appeals, litigation and mutual agreement procedures (MAP).

Deloitte Finland takes an integrated approach to resolving international transfer pricing disputes. Our team has extensive experience in carrying out any level of dispute processes such as administrative appeals, litigation and MAP processes. Due to Deloitte’s global network, transfer pricing dispute teams typically include transfer pricing specialists from both countries in dispute teamed with professionals who specialize in necessary local country requirements.

Business model optimization

The global economic environment is characterized by continuous improvements in technology, an urgency to adopt and implement best practices and processes, and the potential for legislative change. Assessing a multinational's global business model is no longer an optional exercise. Business Model Optimization (BMO) is the process of understanding the demands of operations and of tax law and integrating them into the business model. Deloitte Finland provides high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax requirements in a scalable and sustainable way in order to help business leaders to make effective decisions on an after-tax basis.

Deloitte Finland delivers business model optimization services using the BMO Insight methodology, a set of experience based approaches to developing solutions to a range of tax issues and opportunities.

For more information please contact

Jari Ahonen

Jari Ahonen

Transfer Pricing

Jari johtaa Deloitten siirtohinnoittelupalveluita Suomessa. Hän on neuvonut lukuisia Suomessa toimivia suuria kansainvälisiä yrityksiä erityisesti siirtohinnoitteluun, toimintamalleihin, aineettomiin ... Lisää

Hanna Viilo

Hanna Viilo


Hannan vahva asiantuntemus kansainvälisessä verotuksessa ja siirtohinnoittelussa pohjautuu laajaan kokemukseen Verohallinnosta, teollisuudesta ja konsulttina Deloittella. Hanna avustaa kansainvälisiä ... Lisää