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An overview by Borenius, Taxand Finland
The Finnish Supreme Administrative Court (SAC 2025:61) has recently ruled that acquisition-related advisory costs may be partially deductible as overheads where the acquiring company provides taxable management services to subsidiaries, even if only indirectly owned.
However, costs linked to investors (such as private equity funds) are non-deductible, and mixed-use services (e.g. due diligence, valuations, market research) are only deductible in proportion to their relevance to the company’s taxable activities. The company bears the burden of proof and must demonstrate clear allocation of costs through contracts and records. The decision is especially significant for private equity structures, underscoring the need for careful planning and documentation to safeguard VAT deductions.
Henna Jovio, Anna Ahava and Jussi Pikkujämsä from our Finnish member firm Borenius have published an overview of the ruling and its implications here.
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