Revision of controlled foreign corporation rules and new transfer pricing documentation requirements

In order to bring its CFC Law in line with EC law and the jurisprudence of the European Court of Justice, a proposal is before the Finnish legislature to amend existing provisions. This proposal would narrow the scope of application of the CFC Law, and would amend provisions concerning the definition of a CFC, the determination of the amount of taxable CFC income, the deduction of CFC losses and the foreign tax credit. New documentation requirements are also applicable.