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Administrative Court of Helsinki: Interest expenses allocated to a Finnish PE not deductible as arrangement is regarded as wholly artificial

14 March 2014

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Approved Changes

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Finland; Denmark; European Union

The Administrative Court of Helsinki (Helsingin hallinto-oikeus) gave its decision on 7 March 2014 in the case of 14/0213/4 (published on 19 March 2014). Details of the decision are summarized below. (a) Facts. Subsequent to a restructuring within an international group, the shares of a Finnish company (FI Co) were owned by a Danish company (DK Co). In 2006, the group made further restructuring within the group and consequently, DK Co transferred the shares of FI Co to its subsidiary (Sub Co) (the country of residence of Sub Co is not mentioned in the Court's decision). Sub Co attributed the...