Finland - Distributors with Losses
- M. Raunio
- International Transfer Pricing Journal, 2018 (Volume 25), No 3
- 3 April 2018
Loss-making Finnish subsidiaries are one of the target groups of the Transfer Pricing Unit within the Finnish Tax Administration. The transfer pricing of Finnish subsidiaries with continuous losses has not been accepted to fulfil the arm’s length criteria and, in some cases, the tax authorities have created a deemed services transaction between the Finnish group company and an unidentified foreign associated enterprise. Helsinki Administrative Court published an interesting ruling on the topic in December 2017.