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Finnish Supreme Administrative Court Rules on Interquartile Range in Transfer Pricing Adjustment

20 September 2021

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Approved Changes

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Finland

The Finnish Supreme Administrative Court issued a decision on 13 September 2021 regarding the appropriate value to be used in the interquartile range for a transfer pricing adjustment. The case involved the Finnish parent company of a group that had failed to appropriately charge royalties to its foreign subsidiaries for the use of the company's intangible assets, which resulted in a transfer pricing adjustment for the uncollected royalties. The company agreed with the tax administration on the approach in determining the adjustment, which included the tax administration's selection of the residual profit split method for pricing the fees, with the...