Supreme Administrative Court Ruling on Interest Rate Reflecting Creditworthiness of Individual Companies

Journal
Raunio, M.
Finland
International Transfer Pricing Journal 2011 (Volume 18), No. 4
Format/Price
JournalUSD 45

On 3 November 2010, the Finnish Supreme Administrative Court published a ruling concerning the arm's length interest rate on intra-group loans. This article explains the facts of the case, and considers the ruling and argumentation of each party. The ruling is analysed in light of the OECD Guidelines and some recent transfer pricing rulings of courts from other jurisdictions.