Finland - Supreme Administrative Court Ruling on Interest Rate Reflecting Creditworthiness of Individual Companies
- M. Raunio
- International Transfer Pricing Journal, 2011 (Volume 18), No 4
- 19 July 2011
On 3 November 2010, the Finnish Supreme Administrative Court published a ruling concerning the arm's length interest rate on intra-group loans. This article explains the facts of the case, and considers the ruling and argumentation of each party. The ruling is analysed in light of the OECD Guidelines and some recent transfer pricing rulings of courts from other jurisdictions.