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

The Finnish Tax Administration Dec. 4 posted online updated Guidance No. VH/5315/00.01.00/2023, on the taxation of specific cross-border hybrid arrangements. The updated guidance includes: 1) conditions for the application of the Hybrid Act, for situations where the tax treatment of a financial instrument, supply, entity, or permanent establishment (PE) differs from jurisdiction to jurisdiction, resulting in non-taxation of income or double deductions of expenses or withholding taxes; 2) application of the Hybrid Act to Finnish taxpayers and partners established in other jurisdictions; and 3) establishment of the credit method in hybrid situations involving PEs, under a new DTA with France, ...