Landmark ruling on the tax administration's duty to respect the taxpayers' choices Merja Raunio and Matti Urpilainen
By: Raunio, Merja
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Contributor(s): Urpilainen, Matti.
Material type: 
ArticlePublisher: 2019Subject(s): PRECIOS DE TRANSFERENCIA | DOCUMENTOS | BENEFICIOS | DIVISIÓN | FINLANDIA | JURISPRUDENCIA
In:
International Transfer Pricing Journal v. 26, n. 2, March / April 2019 Summary: The Supreme Administrative Court found in case SAC 2018:173 that the Finnish tax administration did not have the legal right to disregard a taxpayer’s benchmarks and to make reassessments for the years 2006-2008 by applying the transactional profit split method. The taxpayer had not filed incorrect tax returns because it would have been possible for the tax authority to test the arm’s length profitability of intra-group transactions with the transfer pricing methods that the taxpayer had actually used and documented.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2019/2-11 (Browse shelf) | Available | ITPJ/2019/2-11 |
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Resumen.
The Supreme Administrative Court found in case SAC 2018:173 that the Finnish tax administration did not have the legal right to disregard a taxpayer’s benchmarks and to make reassessments for the years 2006-2008 by applying the transactional profit split method. The taxpayer had not filed incorrect tax returns because it would have been possible for the tax authority to test the arm’s length profitability of intra-group transactions with the transfer pricing methods that the taxpayer had actually used and documented.
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