KHO 2024:58: Items Covered by the ATAD Interest Deduction Limitation

Journal
Helminen, M.
Finland
European Taxation 2024 (Volume 64), No. 11
Price USD 45

In this note, the author analyses decision KHO 2024:58 of the Supreme Administrative Court of Finland, which addresses the scope of the Finnish domestic law provision implementing the EU Anti-Tax Avoidance Directive (2016/1164) interest deduction limitation provision. The case deals with the concept of interest under the domestic implementing provision and whether it covers arrangement fees charged by the arrangers of a bond issuance. The case also addresses the possible impact of the Directive on the interpretation of the domestic law concept.