Finland - Landmark Case on the Ability of Tax Authorities To Disregard and Recharacterize Transactions
- M. Raunio
- International Transfer Pricing Journal, 2015 (Volume 22), No 1
- 10 December 2014
The author considers a 2014 ruling by the Supreme Administrative Court regarding the possibility for the tax authorities to recharacterize a taxpayer’s transactions – specifically, the classification of a hybrid loan as debt or equity for tax purposes.