Finland vs Loss Corp, December 2017, Administrative Court, Case no 17/0979/4

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The Finnish tax authorities had made a transfer pricing adjustment to a Finnish marketing and sales subsidiary with continuous losses.
The tax authorities had identified a “hidden” services transaction between the Finnish subsidiary and an unidentified foreign group company.
The Administrative Court ruled in favor of the tax authorities.
The adjustment was not considered by the Court as a recharacterisation.
Reference was made to TPG 2010, paragraphs 1.34, 1.42 to 1.49, 1.64, 1.65 and 1.70 to 1.72.

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Finland vs Loss Corp 29 December 2017 Administrative Court 17-0979-4


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