Finland Supreme Administrative Court Clarifies Taxation of Business Income for CFCs

The Finnish Supreme Administrative Court Jan. 15 posted online Decision No. KHO:2025:4, clarifying the taxation of business income of controlled foreign companies (CFC). The taxpayer, community A, was a silent partner in B fund, which was in turn a silent partner in C fund. The C fund owned the entire share capital of D company. The taxpayer sought clarification on deducting B fund’s income, which indirectly included dividends from D company, by the amount included as taxable income for A in previous years. The Central Tax Board ruled that such income should be fully taxable without any deductions for previously ...