Finland Tax Agency Updates Guidance on Taxation of Specific Cross Border Hybrid Arrangements

The Finnish Tax Administration May 27 updated Guidance No. VH/4966/00.01.00/2021, on the taxation of certain cross-border hybrid arrangements. The updated topics include: 1) key provisions on hybrid regulations; 2) taxable persons and conditions for the application of hybrid provisions; 3) expenditure deductibility related to financial instruments; 4) hybrid transfers and exemptions for financial intermediaries; 5) expenditure deductibility for contractors; 6) expenditure deductibility for payers of performance; 7) provisions for the double deduction of expenditures; 8) hybrid situations involving permanent establishments; 9) offsetting expenditures; and 10) situations related to reverse hybrid units. [Finland, Tax Administration, 05/27/22]

Reference:
View Guidance No. VH/4966/00.01.00/2021 ...