Administrative Court of Helsinki: Interest expenses allocated to a Finnish PE not deductible as arrangement is regarded as wholly artificial

The Administrative Court of Helsinki (Helsingin hallinto-oikeus) gave its decision on 7 March 2014 in the case of 14/0213/4 (published on 19 March 2014). Details of the decision are summarized below. (a) Facts. Subsequent to a restructuring within an international group, the shares of a Finnish company (FI Co) were owned by a Danish company (DK Co). In 2006, the group made further restructuring within the group and consequently, DK Co transferred the shares of FI Co to its subsidiary (Sub Co) (t…