Location savings recognised by the Finnish Supreme Administrative Court

The Finnish Supreme Administrative Court (SCA) rendered a landmark decision on March 4 2013, explains Kennet Pettersson of Ernst & Young. The main dispute concerned location savings and whether such benefits could be allocated to a foreign low cost subsidiary. Though the SCA’s decision rejected the locations savings which were sought to be applied in the case at hand, the decision clearly recognises location savings and the allocation of these benefits to a low cost subsidiary provided similar functions were conducted in Finland before the reorganisation and benefits availed can be clearly crystallised.

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