Tax loss offset decision treated as administrative appeal, not tax procedure appeal, under Finnish law.

The Administrative Court ruled that a tax authority's decision regarding the right to offset losses must be handled as an administrative appeal rather than a tax procedure appeal. The taxpayer argued for specific tax procedural protections, but the court determined the statutory basis for the loss offset decision fell outside the scope of the Tax Procedure Act. Consequently, the court applied the general administrative review standards instead of the specialized tax procedural rules.