Permanent Establishment in VAT

In this case we are advising a Swedish company, a parent of Nordic group, with a complex tax matter in which a possible retroactive constitution of a permanent establishment both for VAT and income tax purposes in Finland had to be prevented and therefore assessed. The concept of permanent establishment is very controversial and with this advance ruling case we are really touching the basis of it.

Permanent Establishment in VAT

In this case we are advising a Swedish company, a parent of Nordic group, with a complex tax matter in which a possible retroactive constitution of a permanent establishment both for VAT and income tax purposes in Finland had to be prevented and therefore assessed. The concept of permanent establishment is very controversial and with this advance ruling case we are really touching the basis of it.

Permanent Establishment in VAT

In this case we are advising a Swedish company, a parent of Nordic group, with a complex tax matter in which a possible retroactive constitution of a permanent establishment both for VAT and income tax purposes in Finland had to be prevented and therefore assessed. The concept of permanent establishment is very controversial and with this advance ruling case we are really touching the basis of it.

The controversy in this case is about a Swedish company, parent of Nordic group, with a complex tax matter in which a possible retroactive constitution of a permanent establishment both for VAT and income tax purposes in Finland had to be assessed.

Consequently, and given the significant Euro amounts subject to scrutiny with regard to the sales possibly subject to VAT in Finland, specific attention was paid to the appropriate means to approach the matter to prevent adverse consequences, while implementing the most practical solution.

The case required some serious procedural planning while acknowledging the significant Euro amounts involved as well as the great ambiguity when reflected upon the applicable legislative framework. Also, the subsequent correction of invoicing with VAT and related discussions with the clients of the company had to be pre-planned carefully e.g., not to affect adversely those client relations, in case of negative outcome of the VAT proceedings.

The case is pending and we expect it to go through the whole appellate regime before we have it finally decided.

The controversy in this case is about a Swedish company, parent of Nordic group, with a complex tax matter in which a possible retroactive constitution of a permanent establishment both for VAT and income tax purposes in Finland had to be assessed.

Consequently, and given the significant Euro amounts subject to scrutiny with regard to the sales possibly subject to VAT in Finland, specific attention was paid to the appropriate means to approach the matter to prevent adverse consequences, while implementing the most practical solution.

The case required some serious procedural planning while acknowledging the significant Euro amounts involved as well as the great ambiguity when reflected upon the applicable legislative framework. Also, the subsequent correction of invoicing with VAT and related discussions with the clients of the company had to be pre-planned carefully e.g., not to affect adversely those client relations, in case of negative outcome of the VAT proceedings.

The case is pending and we expect it to go through the whole appellate regime before we have it finally decided.

The controversy in this case is about a Swedish company, parent of Nordic group, with a complex tax matter in which a possible retroactive constitution of a permanent establishment both for VAT and income tax purposes in Finland had to be assessed.

Consequently, and given the significant Euro amounts subject to scrutiny with regard to the sales possibly subject to VAT in Finland, specific attention was paid to the appropriate means to approach the matter to prevent adverse consequences, while implementing the most practical solution.

The case required some serious procedural planning while acknowledging the significant Euro amounts involved as well as the great ambiguity when reflected upon the applicable legislative framework. Also, the subsequent correction of invoicing with VAT and related discussions with the clients of the company had to be pre-planned carefully e.g., not to affect adversely those client relations, in case of negative outcome of the VAT proceedings.

The case is pending and we expect it to go through the whole appellate regime before we have it finally decided.

Bernhardinkatu 5 A 5

00130 Helsinki, Finland

+358 40 523 2020

office@weckstromattorneys.com

© 2024 Weckström Attorneys Ltd.

Bernhardinkatu 5 A 5

00130 Helsinki, Finland

+358 40 523 2020

office@weckstromattorneys.com

© 2024 Weckström Attorneys Ltd.