Distributors with losses

Resource Information

The work Distributors with losses represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Distributors with losses

Creator

• Raunio, M

Subject

• losses
• case law
• transfer pricing

Language

eng

Summary

Loss-making Finnish subsidiaries are one of the target groups of the Transfer Pricing Unit within the Finnish Tax Administration. The transfer pricing of Finnish subsidiaries with continuous losses has not been accepted to fulfil the arm's length criteria and, in some cases, the tax authorities have created a deemed services transaction between the Finnish group company and an unidentified foreign associated enterprise. Helsinki Administrative Court published an interesting ruling on the topic in December 2017

Citation source

In: International transfer pricing journal. - Amsterdam. - Vol. 25 (2018), no. 3 ; p. 243-249

Geographic coverage

• European Union
• Europe

Language note

English