Finnish Supreme Administrative Court (Korkein hallinto-oikeus, KHO) (the Court) gave its decision on 25 October 2013 in the case of KHO:2013:169. Details of the decision are summarized below.
(a) Facts. A company resident in the United States (US Co) had a permanent establishment (PE) in Finland (FI PE) engaged in producing high-tech sterilization equipment. US Co was planning to restructure its business and applied for an advance ruling from the tax authorities on the tax treatment on such res…