Two Recent Transfer Pricing Preliminary Rulings by the Finnish Supreme Administrative Court

On 13 September 2017, the Finnish Supreme Administrative Court published two rulings concerning transfer pricing. The ruling KHO 2017:145 dealt with the transfer pricing of an ERP system through a SaaS model. The ruling KHO 2017:146 concerned the service provider’s obligation to add a mark-up on its costs when defining an arm’s length service charge. This article explains the facts of these cases and considers the rulings and their implications for the application of the arm’s length standard in Finland.