Finnish Supreme Administrative Court Holds Taxpayer May Base Transfer Pricing on U.S. GAAP

Finland's Supreme Administrative Court issued a decision on 2 June 2021 regarding a taxpayer's use of U.S. GAAP accounting standards in applying the transactional net margin method (TNMM). The case involved a Finnish company that belonged to a group whose parent company was a U.S. corporation. The Finnish company operated as a limited risk distribution company for the group in Finland. In determining the market (arm's length) conditions for the group companies' transfer pricing, the transact…