Recent work | September 5, 2023

Roschier successfully advised a client in a landmark dispute in the Finnish Supreme Administrative Court

Our tax team has successfully advised a client in a landmark dispute in the Finnish Supreme Administrative Court concerning deductibility of interest expenses on cross-border intra-group loans resulting from an internal reorganization (intra-group share acquisition).

This dispute is truly special for two reasons: (i) until to date, the Tax Administration has regularly denied the deductions on interest paid to foreign group companies on loans that have arisen from intra-group reorganizations, but the Supreme Administrative Court now deeply analyzed the business reasons for the reorganization and accepted them and (ii) as regards the interest, the amount of the income tax refunded to the client based on the Supreme Administrative Court’s ruling will be significant.

Roschier assisted the client in explaining that there were genuine business reasons for the intra-group reorganization and the tax avoidance rule was not applicable. Our main advisory team comprised Partner Ossi Haapaniemi and Senior Advisor Merja Raunio.