Transfer of Assets Regime Applicable to US Company's PE under Tax Treaty Non-Discrimination Rule

Journal
Finland
European Taxation 2014 (Volume 54), No. 7
This note examines the Supreme Administrative Court's decision in KHO 2013:169 (25 October 2013), wherein a US resident company claimed that the Finnish transfer of assets rules resulted in prohibited discrimination of its Finnish PE under the Finland-United States Income and Capital Tax Treaty (1989).