2018•International Transfer Pricing JournalRequires access

Distributors with Losses

M. Raunio

Open publisher page 2 citations

Abstract

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.

About this research paper

What this paper is about

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.

Why it matters

OpenAlex reports 2 citations for this work. Citation counts describe recorded attention and do not establish research quality.

Key contribution

A contribution statement is not available in the OpenAlex record.

Method / approach

Method details are not available in the OpenAlex metadata.

Main findings

Findings are not separately available in the OpenAlex metadata.

Limitations

Limitations are not available in the OpenAlex metadata.

Applications

Application details are not available in the OpenAlex metadata.

Available abstract

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.

Key concepts: Transfer pricing, Subsidiary, Business, Database transaction, Tax administration, Accounting, Administration (probate law), Parent company

Related papers

Back to paper searchBrowse research topicsOriginal source
Distributors with Losses — Research Paper | ScholarLens