Central Tax Board rules on treaty characterization of partnership income re Finland-Germany tax treaty

The Finnish Central Tax Board (Keskusverolautakunta, or KVL) ruled on 25 January 2006 (KVL 1/2006) in a case regarding a previously somewhat obscure question as to how partnership income should be characterized for Finnish domestic and tax treaty purposes. The main features of the ruling are summarised below.

(a) Background. Although partnerships are considered to be transparent for Finnish tax purposes, the wording of the Income Tax Law, older case law and certain government bil…