OrbitaxAdministrative Court of Helsinki disallows reclassification of a hybrid loan from a Luxembourg parent as capital contribution due to a TP adjustmen
|Approved Changes|Finland; Luxembourg
The Administrative Court of Helsinki (Helsingin hallinto-oikeus) gave its decision on 29 May 2013 in the case of 13/0844/4. Details of the decision are summarized below.
(a) Facts. A Finnish company (FIN Co) paid interest on a hybrid loan taken from its parent company resident in Luxembourg (LUX Co) and owning 95.7% of the share capital in FIN Co. The Finnish tax authorities as part of the…
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