Finnish Supreme Administrative Court (Korkein hallinto-oikeus, KHO) (the Court) gave its decision on 25 October 2013 in the case of KHO:2013:169. Details of the decision are summarized below. (a) Facts. A company resident in the United States (US Co) had a permanent establishment (PE) in Finland (FI PE) engaged in producing high-tech sterilization equipment. US Co was planning to restructure its business and applied for an advance ruling from the tax authorities on the tax treatment on such restructuring. All the assets and liabilities of the FI PE would be transferred to the newly established Finnish subsidiary (FI Sub), which...