Fortum has received an income tax assessment of approximately EUR 19 million (approximately SEK 173 million) from the Swedish tax authority related to the interests on Group loans in the 2012 tax year. Fortum considers the decision on the additional tax to be without foundation and will appeal the tax authority’s decision.
The Swedish tax authority expects Fortum to pay an additional tax for 2012 for marked priced loans that Fortum’s financing company gave to Fortum’s Swedish subsidiaries. Netherlands, the domicile of Fortum’s European financing company, has already taxed Fortum approximately EUR 7 million for this interest income on the Group’s internal loans in accordance with Dutch tax rate of 25 per cent.
The Swedish tax authority STA claims that Fortum should pay additional income taxes for 2012 in Sweden for the reallocation of loans in Swedish subsidiaries due to Fortum’s restructuring in 2005 and on the loans for acquiring shares in OAO Fortum (former TGC-10) in 2008. The claims are based on changes in tax regulations as of 2009.
STA reassessed the business reasons behind Fortum’s 2005 restructuring and the OAO Fortum acquisition as well as the tax rate of the Fortum finance entities. The Swedish tax authority has for 2012 approved a substantial part of the interest expense as deductible on these loans. The Swedish tax authority has not questioned the loan interest rate paid by Fortum’s Swedish subsidiaries.
In 2012, the year targeted by the additional tax decision, Fortum paid income taxes and other taxes in Sweden totalling about EUR 347 million (about SEK 3.0 billion). Fortum was one of the biggest corporate tax payers in Sweden in 2012.
Fortum’s taxes for the 2012 tax year in all countries of operation totalled EUR 565 million. The company’s total tax rate was 29 per cent.
For additional information, please contact:
Reijo Salo, Vice President, Tax, Fortum Corporation, tel. +358 5045 24443
Fortum’s purpose is to create energy that improves life for present and future generations. Catering to the versatile needs of our customers, we generate, distribute and sell electricity and heat, and offer related expert services. Our operations focus on the Nordic and Baltic countries, Russia and Poland. In 2013, Fortum’s sales totalled EUR 6.1 billion and comparable operating profit was EUR 1.6 billion. We employ approximately 8,800 people. Fortum’s shares are traded on the NASDAQ OMX Helsinki.