Supreme Administrative Court dismissed tax transfer case where tax authority refused to recognize foreign tax credit due to domestic law restrictions.

The Supreme Administrative Court dismissed the applicant's appeal against the Tax Administration's refusal to recognize a foreign tax credit. The applicant argued that the transfer of assets should be exempt from Finnish tax under international agreements, while the Tax Administration contended that domestic provisions on tax transfers precluded such recognition. The court ruled that the specific statutory requirements for tax transfer relief were not met, thereby upholding the administrative decision.