The Supreme Administrative Court (SAC) held in a previous case, SAC 2014:119, that the Finnish domestic arm’s length provision (section 31 of the Act on the Tax Assessment Procedure) does not give the Finnish tax administration legal competence to recharacterize transactions as meant in paragraphs 1.64 and 1.65 of the 2010 OECD Guidelines. Case SAC 2020:35 confirms the SAC’s earlier position: there are certain fundamental private law legal forms and structures that cannot be disregarded by applying section 31 of the AAP. The SAC found that the transfer pricing analysis must depart from the fact that the Belgian subsidiary company providing intra-group financing legally owns the intra-group receivables and, thus, it has acted in the capacity of a creditor. The tax administration had the obligation to set tax consequences accordingly.