- Key Ruling: Finland’s Supreme Administrative Court (SAC 2025:61) confirmed that acquisition-related advisory costs may be partially deductible as overheads—if they support the acquiring company’s taxable business activities, such as management services to subsidiaries.
- Group Structure Neutrality: The Court clarified that VAT deductibility applies even when services are provided to indirectly held subsidiaries, not just directly acquired ones—group structure alone does not restrict the deduction right.
- Burden of Proof & Allocation: Companies must clearly document how costs relate to their own taxable operations versus investor-related activities. Mixed-use services (e.g. due diligence, strategic advice) require careful cost allocation to justify partial VAT recovery.
Source Borenius
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