The Finnish Supreme Administrative Court (SCA) rendered a landmark decision on March 4 2013, explains Kennet Pettersson of Ernst & Young. The main dispute concerned location savings and whether such benefits could be allocated to a foreign low cost subsidiary. Though the SCA’s decision rejected the locations savings which were sought to be applied in the case at hand, the decision clearly recognises location savings and the allocation of these benefits to a low cost subsidiary provided similar functions were conducted in Finland before the reorganisation and benefits availed can be clearly crystallised.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies