The Finnish Supreme Administrative Court (Korkeinhallinto-oikeus, KHO) gave its decision on 17 April 2013 in the case of KHO:2013:72. Details of the decision are summarized below.
(a) Facts. A Oy, a company resident in Finland (FIN Oy), received portfolio dividends from a group's parent company resident in the United Kingdom (UK Co) between 2002 and 2004 during which time Finland applied an imputation credit system. The assets of UK Co consisted of dividends it received from its subsidia…