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FinlandKILA

Consolidation, not top control, decides who is CbCR ultimate parent

A US top holder that prepares no consolidated accounts is not the ultimate parent for public CbCR; the EEA company that consolidates is, so Finland's non-EEA-parent rule does not apply.

By Taxxa AI OyPublished 3 November 2026

Tax

Industry: Across industries

The company that counts as the ultimate parent for public country-by-country tax reporting is the one that prepares the largest consolidated accounts, not simply the highest company in the control chain.Kirjanpitolautakunta The Accounting Board applied that test in statement 2160 on Accounting Act chapter 7 bKirjanpitolautakunta, concerning Finnish company A Oy whose indirect top holder in the United StatesKirjanpitolautakunta prepares no consolidated accountsKirjanpitolautakunta.

A Oy is a medium-sized or large EU company within public CbCR by size, governance, control and turnover. Its direct parent B sits in another EEA state and prepares consolidated accounts for 2025 covering A OyKirjanpitolautakunta Kirjanpitolautakunta. Above them sits C in the United States, which indirectly owns all of B and controls B, which owns all of A OyKirjanpitolautakunta. Group turnover exceeds EUR 750 million, but C cannot supply the reporting data, is not listed, and neither prepares nor must prepare consolidated accountsKirjanpitolautakunta. The applicant asked how the duty is assessed, how far A Oy must seek data from C or instead from B, what to report if data never arrive, and what good accounting practice requires.

The definition is decisive. Under Article 48a of the Accounting Directive, ultimate parent means the undertaking preparing the largest consolidated accountsKirjanpitolautakunta, and Article 48b(4) ties both the trigger and the report content to that undertaking's consolidated revenues and accounts. Accounting Act 1:10 defines ultimate parent the same wayKirjanpitolautakunta. Chapter 7 b, added by Act 238/2024 to implement Directive (EU) 2021/2101, follows that structure. KPL 7 b:2 covers the Finnish subsidiary of a non-EEA ultimate parentKirjanpitolautakunta: under 7 b:2.1 a report must be published when the parent's consolidated turnover exceeded the threshold in both the past and preceding year, and under 7 b:2.2 the subsidiary must ask the ultimate parent for data and, if the data still do not arrive, publish a report from data held or obtained with a statement that the parent did not supply them.

The Board recalled KILA 2096/2025, which reads chapter 7 b in line with the directive where national wording is unclear, and KILA 2127/2026 on the priority of the non-EEA undertaking's own report under 7 b:4.

On these facts C prepares no consolidated accounts while B prepares the accounts covering A Oy, with no higher consolidating undertaking shownKirjanpitolautakunta Kirjanpitolautakunta Kirjanpitolautakunta. The regime provides a missing-data procedure but no option to redefine the ultimate parent by top control aloneKirjanpitolautakunta, so the transparency objective does not justify departing from Article 48a. What matters is who consolidates, not who sits highest. B is therefore the ultimate parent for this regimeKirjanpitolautakunta, and C's ultimate control does not alone make C the ultimate parent hereKirjanpitolautakunta.

That classification removes the case from KPL 7 b:2Kirjanpitolautakunta, which covers control by a non-EEA ultimate parent. Since B sits in the EEA, A Oy's position is not assessed under that sectionKirjanpitolautakunta. If B meets the conditions, the duty follows the national law applicable to BKirjanpitolautakunta, on which the Board takes no view for other EEA states. The follow-on questions on requesting data, on reporting only own data, on including subsidiaries, and on fallback content therefore needed no separate answer.

For practice the guidance is documentation. Good accounting practice requires A Oy to establish in its accounting material or otherwise in documented form the relevant group structure, which undertaking is the ultimate parent, and how the duty follows from the applicable legislationKirjanpitolautakunta, so the existence or absence of a duty can be evidenced.

Legal basis: kirjanpitolaki 1:10 and 7 b:2; tilinpäätösdirektiivi 2013/34/EU, 48 a artikla and 48 b artiklan 4 kohta, as amended by direktiivi (EU) 2021/2101; laki 238/2024.

Identify the undertaking that prepares the largest consolidated accounts and document why public CbCR is or is not assessed under KPL 7 b:2 before seeking data from the top holder.

Sources

Kirjanpitolain 7 b luvun soveltamisesta