Late 2021, Finland implemented a regulation concerning taxation of reverse hybrid arrangements included in article 9a of ATAD2 directive (Council directive (EU) 2017/952 amending Directive 2016/1164). The new rules have been implemented in Section 8a of the Finnish act on taxation of cross-border hybrid arrangements (Hybrid Act) and have been applied for fiscal year 2022 onwards.
Finland’s Ministry of Finance on January 13 announced the results from a research report reviewing the effectiveness of subsidies for research and development (R&D) activity, stating that the results support the use of R&D tax incentives as “proper policy” in Finland; however, while the report found that open-use R&D subsidies like tax incentives are . . .
Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .
Visa Randell, LL.M., M.Sc. (Econ.), Helsinki, discusses two important transfer pricing decisions of Finlands’ Supreme Administrative Court, released April 2; one concerns a sales company that incurred losses over multiple years and the other involves the tax authority’s attempt to restructure a transaction for transfer pricing purposes . . .
The United Arab Emirates and Finland on March 27 signed an agreement on the exchange of information . . .
Finland’s President on June 22 appointed Petteri Orpo as Minister of Finance . . .
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