Tag: Deductible group contributions

Finland vs A Oy, April 2023, Supreme Administrative Court, Case No. KHO:2023:32

Finland vs A Oy, April 2023, Supreme Administrative Court, Case No. KHO:2023:32

During the FY 2010, A OY had made a group contribution to another domestic group company. When the 2010 tax assessment was carried out, A OY’s profit from business activities after deducting the group contribution was determined to be EUR 0. The French company B was part of the same group as A OY. For B, a transfer pricing adjustment had subsequently been made whereby an addition of EUR 656,339 was made to B’s taxable income based on payments to A OY. In the arbitration procedure between the French and Finnish authorities under the Arbitration Convention, the said transfer pricing adjustment was considered to be compatible with the arm’s length principle. The Tax Administration implemented the final result of the arbitration procedure by means of a consequential amendment to A OY’s taxation for 2010. An amount of EUR 656,339 was deducted from the company’s income from business activities, but the company was not assessed a loss for the source of ... Read more