Favourable tax decision in Belgium for Fortum's financing company

The Belgian Court of Appeal in Antwerp has on 13 January 2016 decided in favour

of Fortum's appeal regarding the 2008 taxation of Fortum EIF NV, Fortum's

Belgian financing company. Based on legal analyses and supporting legal

opinion, Fortum has made no provisions for the tax in the financial statements.

The Belgian tax authorities (BBI) can appeal the decision to the Hof van

Cassatie (the Supreme Court).



The decision concerns Fortum's Belgian financing company, Fortum EIF NV, which

granted internal financing to a Swedish group company for financing an

acquisition in Russia. The Belgian tax authorities argued that Fortum EIF

should not benefit from the notional interest deduction (NID) regime in

Belgium. As Fortum EIF was established for genuine business reasons to manage

financing risks, the Court approved Fortum's appeal.



The income tax paid in Belgium for 2008 was EUR 36 million. Fortum has also

appealed the income assessments of Fortum EIF NV for years 2009, 2010 and 2011

in Belgium. Fortum's appeals concerning the years 2009–2011 are pending, and

Fortum expects the remaining years to follow the decision from the Court of

Appeal for 2008. In total, the taxes for cases for 2008–2011 amount to EUR 98

million. The additional taxes have already been paid by Fortum in 2012–-2015,

and they have been booked as receivables.



Fortum Corporation

Corporate Communications



Further information:

Reijo Salo, Vice President, Tax, tel. +358 50 45 24443



Fortum

Fortum’s purpose is to create energy that improves life for present and future

generations. Fortum’s expertise is in CO2-free and efficient electricity and

heat production. The company also offers energy-related products and expert

services to private and industrial customers and energy producers. Fortum’s

main areas of operation are the Nordic and the Baltic countries, Russia and

Poland. In 2014, the annual sales (excluding the divested electricity

distribution business) totalled EUR 4.1 billion, and comparable operating

profit was EUR 1.1 billion. The company employs approximately 8,000 people.

Fortum’s share is listed on Nasdaq Helsinki. www.fortum.com