The Finnish Supreme Administrative Court (SAC) issued two significant precedents on 23 September 2019 in cases, which substantially limit the concept of consideration for transfer tax purposes. According to the SAC, transfer tax was not payable on compensation paid for shareholder loan receivables that the purchaser has acquired in connection with a share acquisition. This interpretation derogates from the observed practice. In the other case the liabilities the purchaser had assumed for the target company’s future debts were not regarded as compensation on which transfer tax is payable. These new precedents may justify the reclaim of transfer tax on prior transactions.


Discover More: Landmark precedents on limiting transfer taxation in Finland



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