Life estate holder's subsequent improvements to property constitute a taxable gift to life tenant.

The Administrative Court ruled that improvements made by a life estate holder to the property immediately following a gift constitute a taxable gift to the life tenant. The mother gifted the building to her daughter while retaining a life estate, and shortly thereafter, the mother performed major renovations. The court held that these renovations increased the value of the property received by the daughter, thereby creating a taxable gift event under Finnish tax law.