Back to News

Tax dispute between Finland and Austria resolved

Tax dispute with regard to two Finnish subsidiaries of Borealis AG resolved through Mutual Agreement Procedure

On 7 June 2019, the Finnish and Austrian Tax Authorities reached an agreement on two cases regarding the taxation of Borealis Technology Oy and Borealis Polymers Oy. The dispute was resolved through a Mutual Agreement Procedure (MAP) between Finland and Austria. Borealis welcomes the agreement, which finally eliminates double taxation.

The disputes emerged during the years 2014-2015, after Borealis Technology Oy and Borealis Polymers Oy had received re-assessment decisions from the Finnish Tax Authority regarding the intercompany licence agreements in place. The Finnish Tax Authority held the view that the Finnish companies had not actually licenced their intangible assets, but had instead sold them to their Austrian parent company Borealis AG.

In both cases, the MAP agreement has confirmed the nature of the intercompany licence agreements, albeit with an increase of the applicable licence fees.

The purpose of the MAP is to avoid double taxation of the same income in Finland and Austria. The MAP is based on the Double Taxation Convention between Austria and Finland as well as on the EU Arbitration Convention Procedure.

As a responsible company, Borealis always complies with the laws and regulations in every country in which it operates. While Borealis is prepared to pay its fair share of corporate income tax, it seeks to avoid being taxed multiple times on the same income. Borealis believes that clear and consistent taxation practices within the European Union are needed for companies to ensure their competitiveness and future growth.

As the second largest polyolefins producer in Europe, Borealis has a strong asset base and a workforce of approximately 6,400 in the region and is strongly committed to its European operations. Borealis employs approximately 1,900 employees in Austria and 900 in Finland.

END

For further information, please contact:
Virginia Mesicek
Sr. Manager a.i., External Communications
tel.: +43 1 22 400 772 (Vienna, Austria)
e-mail: virginia.mesicek@borealisgroup.com

Media Contact
Group Media desk
Virginia Wieser, Lena Lehner
+43 1 22 400 899 (Vienna, Austria)
media@borealisgroup.com

Related News

Media Release – 26/04/2024

​​OMV and Borealis sign long-term supply agreements with TOMRA for recycling feedstock produced from mixed waste​

Read more

News – 18/04/2024

Borealis and Borouge expand HVDC production capacity to meet the needs of the energy transition

Read more

Media Release – 09/04/2024

Borealis invests EUR 4.5 million in Porvoo steam cracker, enabling increased share of circular raw materials used in production

Read more

Media Release – 02/04/2024

Borealis further expands its advanced mechanical recycling capacity with closing the acquisition of Integra Plastics AD

Read more

Media Release – 28/03/2024

FDA clears Borealis’ Borcycle™ M recycled plastics for use in food-grade packaging

Read more

News – 27/03/2024

Update on the Kallo Case

Read more

Media Release – 26/03/2024

Borealis and AKVA group launch groundbreaking Polarcirkel™ workboat hull crafted from renewable feedstock-based plastic

Read more

News – 22/03/2024

Annual Report 2023 published

Read more

Media Release – 20/03/2024

Project STOP marks further major milestones in 2023 and makes significant progress in the Project STOP Banyuwangi Hijau expansion program

Read more