Tag: Marketing services

Finland vs Corp, September 2017, HFD:2017:145

Finland vs Corp, September 2017, HFD:2017:145

Ruling by the Finnish Supreme Administrative Court on enterprise resource planning and intra-group services arrangements. A Oyj had provided its subsidiaries with supply chain services, marketing and brand management services as well as personnel and computer services. The services offered by A Plc mainly consisted in the coordination and harmonization of the Group’s operations. A’s turnover consisted almost exclusively of the service fees received from the sale of these administrative services. As a service charge, A Oyj had charged the amount of the costs incurred in producing the services without the amount of the bonus. On the basis of the tax audit findings, the Tax Administration has added to the taxed income of A plc with ex post taxation and tax corrections to the detriment of the taxpayer the sums equivalent to seven percent payables. The amount of the bonus was established on the basis of a comparison of the Bureau van Dijk Amadeus database with the tax audit. As ... Continue to full case
Canada vs. Marzen Artistic Aluminum. January 2016

Canada vs. Marzen Artistic Aluminum. January 2016

The intercompany transactions at issue involved fees paid to the company’s wholly-owned Barbados based subsidiary during taxation years 2000 and 2001 for sales, marketing and support services. The Tax Court of Canada had determined that it was appropriate to apply the CUP method rather than the TNMM, which was advocated by the company’s expert. Canada’s Federal Court of Appeal upheld the decision by the Tax Court of Canada, which in 2014 ruled that the Canada Revenue Agency had largely been correct in reassessing the taxable income of Marzen Artistic Aluminum Ltd. Canada vs Marzen-v-the-Queen ... Continue to full case