Finnish Supreme Administrative Court rules on Liechtenstein dividend withholding tax not creditable against Finnish tax on CFC income

The Supreme Administrative Court of Finland (Korkein hallinto-oikeus) gave its decision on 15 February 2010 in the case of KHO:2010:7 and held that the tax withheld on dividends from Liechtenstein was not creditable against the tax imposed in Finland on income of a controlled foreign company (CFC). Details of the decision are summarized below.

(a) Facts. A was a resident of Finland who fully owned the share capital of B Ltd., a company resident in Liechtenstein…