"I'd say it's been a good year really. You have to take into consideration that Finland is in much the same situation as the rest of Europe," said a partner. Despite the economic ructions, things do seem to have been fairly stable over the past 12 months.Transfer ...
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"I'd say it's been a good year really. You have to take into consideration that Finland is in much the same situation as the rest of Europe," said a partner. Despite the economic ructions, things do seem to have been fairly stable over the past 12 months.
Transfer pricing dominates the agenda. "Transfer pricing is the hot topic here. The tax office has formed a special group just for corporations," said Ossi Haapaniemi of Hannes Snellman. Another partner commented: "The main focus in the tax audits is transfer pricing. This has resulted in a considerable number of transfer pricing disputes where monetary values are huge."
Changes in the law, as a whole, are more in the consultancy stage at the moment. "The ministry of finance has given out new draft rules. We will have to wait and see if they are introduced in 2013," said a partner. "There have been no other real changes in the law; the draft concerning interest deduction limitation rules is the biggest news. May be new group taxation rules but they are further away," added Haapaniemi. There is definitely a wait and see attitude toward seeing if these new rules will take effect in the next two to three years.
Other partners predicted more specific changes: "It is likely that Finland will enact earnings stripping rules, most likely as from January 1 2013. This will impact greatly to the Finnish tax planning environment and also it will refocus the tax advisory work."
Keeping in line with the wider European trend, Finnish tax practitioners report a renewed vigour from the tax authorities to raise revenues. This isan knock-on effect of the economic contraction felt across the continent.
"The tax authorities are very aggressive now," said one corporate tax partner. "Debt pushdowns are being challenged, and the tax authorities are going after double-deductions, double-dips," added another.
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