Transfer of Assets Regime Applicable to US Company's PE under Tax Treaty Non-Discrimination Rule

Journal
Author
Nieminen, M.
Country
Finland
Published Date
Issue
European Taxation 2014 (Volume 54), No. 7
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This note examines the Supreme Administrative Court's decision in KHO 2013:169 (25 October 2013), wherein a US resident company claimed that the Finnish transfer of assets rules resulted in prohibited discrimination of its Finnish PE under the Finland-United States Income and Capital Tax Treaty (1989).