Finland - Transfer of Assets Regime Applicable to US Company's PE under Tax Treaty Non-Discrimination Rule
- M. Nieminen
- European Taxation, 2014 (Volume 54), No 7
- 10 June 2014
This note examines the Supreme Administrative Court's decision in KHO 2013:169 (25 October 2013), wherein a US resident company claimed that the Finnish transfer of assets rules resulted in prohibited discrimination of its Finnish PE under the Finland-United States Income and Capital Tax Treaty (1989).