author_orbitax
Orbitax

Share This Article

Finnish Supreme Administrative Court Holds Taxpayer May Base Transfer Pricing on U.S. GAAP

09 June 2021

|

Approved Changes

|

Finland

Finland's Supreme Administrative Court issued a decision on 2 June 2021 regarding a taxpayer's use of U.S. GAAP accounting standards in applying the transactional net margin method (TNMM). The case involved a Finnish company that belonged to a group whose parent company was a U.S. corporation. The Finnish company operated as a limited risk distribution company for the group in Finland. In determining the market (arm's length) conditions for the group companies' transfer pricing, the transactional net margin method was used with determinations made on the basis of U.S. GAAP. In its 2011 financial statements, the Finnish company made a...