Amendments to Finland's CFC regime

After the 2006 judgment of the European Court of Justice in Cadbury-Schweppes, it was clear that Finland's CFC regime, introduced in 1995, had to be amended in order to bring it into line with the ECJ's judgment. Finland amended its CFC regime accordingly, with effect from 1 January 2009. After giving some background and describing Finland's old regime, the article discusses the 2009 changes, including (among others) the exclusion of certain states from the CFC regime, the treatment of permanent establishments and losses, and the elimination of double taxation.