Finland - Centralization of Intangibles and Transfer Pricing under BEPS and Finnish Tax Law
- S. Penttilä; A. Isomaa-Myllymäki
- European Taxation, 2018 (Volume 58), No 2/3
- 22 January 2018
This article discusses principal and holding company structures used by MNE groups, in particular those related to intangibles, including an assessment of such structures under the arm’s length principle of the OECD Transfer Pricing Guidelines and Finland’s domestic transfer pricing legislation. The article examines the pressure to change existing structures as a result of the OECD BEPS Project.