The Finnish Tax Administration issued a preliminary decision (ennakkoratkaisu) numbered 2026/17, which addresses a specific tax case concerning corporate income tax and the allocation of profits between related entities. The decision clarifies the interpretation of Sections 4 and 5 of the Income Tax Act regarding transfer pricing adjustments when a multinational group reorganizes its ownership structure. It outlines the criteria that must be met for the Tax Administration to accept a profit allocation method, emphasizing the need for arm‑length principles and documented benchmarking analyses. The guidance also details the procedural steps for taxpayers to request confirmation of their chosen method, including the submission of supporting documentation and the timeframe for the Administration's response. Additionally, the decision warns that any deviation from the approved method without prior approval may result in reassessment and penalties. By providing a clear framework, the ruling aims to reduce uncertainty for multinational corporations operating in Finland and to ensure consistent application of transfer pricing rules across similar cases. The summary also highlights that the decision will be published on the Tax Administration's website and will serve as a reference for future rulings on comparable matters.