Finnish Court Holds Goodwill Not Subject to Exit Tax in EU Cross-Border Merger

A decision from Finland's Supreme Administrative Court has been published concerning whether the transfer of goodwill as part of a merger between a Finnish company and a Swedish company may be included as part of the tax base for exit tax purposes. The case involves the merger of a Finnish company with its Swedish parent as part of an overall restructuring that involves the conversion of the Finnish and certain other EU subsidiaries of the group into branches of the Swedish parent. In 2016, …