An analysis by Borenius, Taxand Finland
The Finnish Supreme Administrative Court (“SAC”) issued on 31 August 2023 two new precedents (KHO:2023:74 and KHO:2023:75) on the Finnish income tax treatment of the so-called US flip structures where a new US parent entity is inserted into an existing structure.
The cases considered share-for-share exchange and merger structures. Based on the precedents, an income tax neutral US flip is generally available through a merger structure, whereas a tax neutral share-for-share exchange to US is not possible.
In their latest Legal Alert, Heikki Wahlroos and Mikko Vesikivi from our Finnish firm, Borenius, delve into the detail of the rulings and the impact for companies.
Find out more here.
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