Finland transfer pricing rules analyzed in landmark court rulings
This article focuses on two tax cases revolving around transfer pricing and their respective treatments. ... - Continue reading
Category: Finland
BEPS Changes To Nordic Double Tax Agreement To Take Effect
The double tax agreement between the Nordic countries will be updated with new anti-tax base erosion and profit shifting provisions with effect from January 1, 2020. ... - Continue reading
Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI
The Australian government on August 9 published the synthesized texts of Australia’s bilateral tax treaties with France, Finland, and Malta as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
NBI probe in Turku targets real estate firm, nabs third suspect
A large-scale police operation into money laundering appears to have targeted the Airiston Helmi real estate firm, led by a Russian man with Maltese citizenship. An exceptionally large police operation took place in southwest Finland this weekend, in what the National Bureau of Investigation (NBI) said was an extensive search… – Continue reading
China’s Hong Kong signs tax pact with Finland
HONG KONG, May 24 (Xinhua) — The government of China’s Hong Kong Special Administrative Region (HKSAR) on Thursday signed a comprehensive avoidance of double taxation agreement (CDTA) with Finland, further expanding the HKSAR’s tax treaty network. The HKSAR government’s Secretary for Financial Services and the Treasury James Lau and Consul-General… – Continue reading
New Finland-Spain Tax Treaty Effective 2019
A new tax treaty between Finland and Spain, which will broaden the Finnish Government’s taxing rights with respect to pension income, will be effective from 2019, according to the Finnish Ministry of Finance. The ministry said in a release issued on May 17 that under the existing tax treaty, pension… – Continue reading
Court classifies medical firm tax planning as evasion
Tax authorities reviewed a case in which a doctor worked at a limited partnership firm and was paid via a limited liability company. The court described the arrangements as tax evasion. Many professionals would prefer to pay taxes on capital income because the tax burden is lighter than on earned… – Continue reading
Belgian Tax Authority To Search For Taxpayers Using Foreign Crypto Exchanges
The Belgian Special Tax Inspectorate (STI) is looking for Belgian individuals who have invested in cryptocurrencies in foreign exchanges, local news outlet De Standaard reported Friday, March 2. After receiving information from Finnish authorities that several Belgian taxpayers had been trading on Finnish crypto exchanges, the STI started looking into… – Continue reading
Bahamas Converts Finland Taxation Deal To Automatic
THE Bahamas yesterday upgraded its tax information exchange agreement with Finland to the automatic variety, as it bids to meet global standards by September 2018. K P Turnquest, deputy prime minister, signed the Protocol to Amend the Tax Information Exchange Agreement between the Bahamas and Finland, with the latter’s ambassador… – Continue reading
The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context
The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of… – Continue reading
Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance
A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading
Finland allowed to tax pensioners in Portugal
Following pressure from the Finnish government and public opinion in the Scandinavian country, Helsinki has announced a deal which will allow it to come after expat pensioners, who are residing in Portugal, for income tax payments from which they were previously exempt. Other EU states have also expressed their aversion… – Continue reading
Taxman sets police on Finns coming clean on undeclared overseas income
Finns alarmed by cracks in the previously iron-clad Swiss banking secrecy have come forward to volunteer information about undeclared overseas income to Finnish tax authorities. They were hoping for immunity from fines or criminal sanctions but dozens now face police investigations. The Finnish Tax Administration has requested police investigations into… – Continue reading
Finnish Expats In Portugal Face Higher Taxes
Finland will have “more possibilities” to tax Finnish pensioners living in Portugal under a recently revised bilateral double taxation avoidance treaty, the Finnish Government has said. The new agreement was signed on November 7 by Portuguese Finance minister Mario Centano and his Finnish counterpart Petteri Orpo, who declared himself “very… – Continue reading
New Finland-Spain Tax Treaty Postponed
The introduction of a new double tax avoidance treaty between Finland and Spain will be delayed by at least one year due to the ongoing political stalemate in Spain. The Finnish Finance Ministry announced on October 7 that the application of the agreement, which was expected to begin on January… – Continue reading
Finnish Royalties To Estonia No Longer Taxed
The Finnish Tax Administration has confirmed that the payment of Finnish-sourced royalties to taxpayers in Estonia are not subject to withholding tax under the Finland’s double tax avoidance treaty with the Baltic state. In a tax administration bulletin issued on October 3, the Finnish tax authority said that as of… – Continue reading
OECD Advises Finland On Growth-Friendly Tax Reforms
A revenue-neutral modification of Finland’s tax structure could boost the nation’s economic growth, the Organisation for Economic Cooperation and Development said in a recently released report. Finland has already adopted some measures to make the tax structure more growth friendly in recent years, the report, Boosting Productivity in Finland, said…. – Continue reading
Beyond FATCA, Costa Rica Adopts “GATCA” Tax Reporting Measures
The unpopular Foreign Account Tax Compliance Act (FATCA) of the United States has set off a rash of similar legislation around the world, and Costa Rica has been eager to adopt these international asset reporting treaties, which many taxpayers consider overreaching and in violation of financial privacy. The Costa Rica… – Continue reading
David Cameron’s finances touched a nerve – tax openness is the answer
Nearly half of people say the Prime Minister’s handling of his finances was ‘morally repugnant’, according to our opinion poll, and they support public tax returns for all As the fallout from the fallout from the Panama Papers leak begins to settle, the Prime Minister is left contemplating the damage… – Continue reading
UAE, Finland sign agreement on exchange of information for tax purposes
ABU DHABI: The United Arab Emirates and the Republic of Finland have signed an agreement on the exchange of information for tax purposes between the two countries. The agreement was signed by Younis Haji Al Khoori, Undersecretary of the Ministry of Finance, MoF, and Riitta Swan, Ambassador of Finland to… – Continue reading
Uzbekistan, Finland sign protocol to double taxation avoidance agreement
Uzbekistan and Finland signed a protocol on amendments to the Uzbek-Finnish intergovernmental agreement on avoidance of double taxation and prevention of income tax evasion, the Uzbek foreign ministry’s statement posted on its website said. Uzbekistan and Finland signed the agreement on the avoidance of double taxation and prevention of income… – Continue reading
Kenya: Treasury Defends Controversial Mauritius Tax Agreement
Treasury is still fighting to keep a tax agreement out of parliament after a lobby group sued them over a pact it signed with Mauritius back in 2012. The double taxation avoidance agreement allows firms registered in the two countries to pay taxes in only one country. It also allows… – Continue reading
Tanzania: Managing Tax Risks – Double Tax Treaties and Implications
Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading
S. Korea, Macau to sign tax information exchange agreement
Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading
Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals
The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading
Finland: Transfer pricing documentation rules, country-by-country reporting proposal
The Ministry of Finance on 21 December 2015 released for public comment a proposal to revise the transfer pricing documentation rules and introduce country-by-country (CbC) reporting. The proposal—released as a draft bill—includes CbC reporting, master file and local file requirements, and penalty provisions, and generally follows the recommendations of the… – Continue reading
Turkmenistan, Finland agree to avoid double taxation
Majlis (Parliament) of Turkmenistan has ratified an agreement with the government of Finland for the avoidance of double taxation with respect to taxes on income during the regular meeting, the Turkmen government said Jan.13. Turkmenistan believes that namely innovations ensured Finland’s competitiveness at international level. The message of the State… – Continue reading
Spain and Finland sign new treaty to avoid double taxation and to fight tax fraud
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
Double taxation avoidance
India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading
IP BOX: Italian and European Legal Framework
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
Nokian to Appeal Additional Tax Bill
Nokain Tyres is appealing a tax adjustment for 2007-2010 that requires the tiremaker to pay an extra 87 million euros. The adjustment includes an additional 55 million euros in additional taxes and 32 million in punitive taxes that must be paid by January 2016, Tyres and Accessories reported. Nokian described… – Continue reading
Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010
the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading
Finland’s Basic Income
The government of Finland is planning to be the first European country to provide to each adult citizen a basic income, replacing its existing welfare, social security, and unemployment payments. A pilot program is planned for November 2016, to be implemented by the Finnish Social Insurance Institution. The replacement of… – Continue reading
Kenya and South Africa tax deal takes effect in January
The Kenya-South Africa double taxation agreement comes into force from January 1. An announcement in the November 19, South African government gazette says the agreement applies for taxes withheld at source. “A resident of Kenya will not be taxed on any South African business profits, unless it carries on business… – Continue reading
Yle programme: Finnish corporations cold-shoulder EU anti-tax planning efforts
Finnish companies continue to take advantage of legal tax planning to shelter their profits from taxation. According to Yle’s Ajankohtainen kakkonen current affairs programme, state-owned firms are among those that have been dragging their feet on reporting income from their foreign subsidiaries. The European Union is making an effort to… – Continue reading
Minister Toivakka in tax avoidance row
Finland’s Minister for Foreign Trade and development, Lenita Toivakka, has admitted being involved in a scheme to reduce tax liabilities on a multi-million euro shopping centre development in Mikkeli. She insisted that the arrangement was legal as well as commonplace for international property investors. Finland’s Minister for Foreign Trade and… – Continue reading
The Latest South African Tax Proposals are Far-reaching
There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading
Brazil: Non-Applying Of Withholding Income Tax Over Foreign Remittances Of Remuneration Of Technical Services Supplied By Non-Residents In Brazil
The Brazilian Federal Revenue – RFB and the General Attorney of the National Treasury – PGFN changed the understanding that they shared in regard to the applying of Withholding Income Tax (IRRF) over foreign remittances of remuneration of technical services supplied by non-residents in Brazil. Before that, the RFB1 and… – Continue reading
I-T dept slaps fresh tax notice on Nokia India
Firm wants the new demand included in ongoing talks between India and Finland to resolve Rs 2,000-cr tax dispute Income Tax Department has slapped fresh tax notice on Nokia India, tax authorities said today. The Finnish telecom firm, however, wants the fresh demand to be included in the ongoing negotiations… – Continue reading
Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs
On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading
It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th
The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading
Minister on board of tax haven firm
Anne Berner, who serves as Minister of Transport and Communications, serves on the board of a Luxembourg firm involved in tax planning. This is the first time a Finnish minister has been known to have been involved in such a company. Finland’s Transport minister is a board member at a… – Continue reading
IFA Annual Congress: practical protection of tax payers’ rights and BEPS in focus
There are often a few major issues on everyone’s lips in the international community of tax lawyers. This was the case also at The International Fiscal Association’s (IFA) 69th Congress in Basel, Switzerland. One of the main subjects in the congress was how tax payers’ rights can be most efficiently… – Continue reading
EU States Told To Address Widening VAT Gap
Tax Commissioner Pierre Moscovici has urged European Union (EU) member states to “take the steps needed to fight tax evasion and tax fraud,” after new figures showed that the value-added tax (VAT) gap did not narrow in 2013. According to a new Commission report, the total amount of VAT lost… – Continue reading
EU loses 168b euros in sales tax fraud, errors
BRUSSELS: European Union (EU) countries lost 168 billion euros (US$187 billion, S$266 billion) in sales-tax revenue in 2013 mostly due to fraud and errors, the European Commission said on Thursday (Sep 3). According to a commission study which covered 26 of the EU’s current 28 members, a total 15 percent… – Continue reading
Luxembourg performs poorly in anti-money laundering index
In an assessment of money laundering and terrorism financing risks, Luxembourg scored in the bottom half of a ranking of 152 countries carried out by the Basel Institute on Governance, reports the Luxemburger Wort. The institute says that its AML (Anti-Money Laundering) Index is the only such review carried out… – Continue reading
Ireland making ‘little or no’ effort to curb corruption – report
Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading
Tax inversions are a symptom of much bigger problems with America’s corporate-tax regime
IT IS the corporate equivalent of burning the American flag. A “tax inversion” is a manoeuvre in which a (usually American) firm acquires or merges with a foreign rival, then shifts its domicile abroad to reap tax benefits. A spate of such deals last year led Barack Obama to brand… – Continue reading
OECD Tracks Tax Admin Changes In 56 Countries
The Organisation for Economic Cooperation and Development (OECD) said in a recent report that improving taxpayer services, while making non-compliance harder, is helping revenue bodies increase their efficiency and allowing governments to finance important programs that will further benefit their citizens. According to Tax Administration 2015, which looks at 56… – Continue reading
