The Finnish tax administration has continued to seek out every drop of available revenue, which has been a common trend over the past couple of years. There has particularly been more focus on tax planning, restructuring and audits as the authorities try to collect more revenue. As Janne Juusela, head of tax at Borenius, Taxand Finland, puts it: "The biggest thing in the Finnish tax market is that the Finnish tax administration have been very aggressive in tax audits and in the court cases that are pending."
Despite this increasingly aggressive approach, the authorities are very cooperative and open to discussions with taxpayers and advisers. "There is of course a lot of work ahead in building mutual trust but the open attitude and the aim to shift focus from retroactive auditing to proactive and even real-time monitoring is in any case a good start," said Petteri Rapo, senior associate and acting CEO of Alder & Sound. "If continued, this progress will hopefully promote building a common understanding between the tax authorities, companies and advisers on the complex tax and transfer pricing matters which in turn would improve the predictability of taxation and would also allow the tax authorities to better focus their monitoring efforts."
The Finnish economic climate is slowly recovering after the downturn and recession and taxpayers are preparing for potential international tax implementations. Although it has been a relatively stable year, with few changes to tax legislation, uncertainty has continued to spread. The OECD's BEPS Project remains a vague concept in Finland and little is known of when it will be implemented.
"Some of the structures that multinational enterprises have used are being challenged more and more now and it is sort of an unclear area at the moment because it is not certain that you can actually challenge something based on OECD's recommendations, because the Finnish constitution says that if you want to impose taxes you have to make a law and pass it through the Finnish parliament and obviously it is not a law of the Finnish parliament," said Heikki Vesikansa, tax partner at Hannes Snellman. "It is a bit of a vague area at the moment of how much more income revenue the tax authorities could raise just by applying these recommendations."
Although it is not yet known when many of the BEPS Action Points will be implemented, the amended EU parent-subsidiary hybrid mismatch prevention rules were implemented from 2016 onwards. The Bill was approved on October 1 2015 to amend the Finnish Business Income Tax Act by limiting the corporate entities' right to receive tax-exempt dividends. The Bill was presented to parliament on October 2 2015.
Contact: Janne Juusela, Head of Tax Practice
Borenius is one of the leading commercial law firms in Finland. We provide innovative business law services in Finland, New York U.S., Russia and the Baltic region, through our associated Borenius Group offices in Estonia, Latvia and Lithuania. Our Tax group provides services in the areas of direct and indirect taxation with particular emphasis on M&A, capital markets and finance, investment activities, formation of private equity funds and launching of new businesses.
Borenius is, exclusively, Taxand Finland, giving clients access to over 2,000 Taxand advisors worldwide.
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The young firm Alder & Sound provides multinational clients with a range of tax services including corporate and international tax, transactions, restructuring, finance, VAT and transfer pricing. The team of 15 professionals, including three partners, is headed by Reima Linnanvirta. He specialises in tax planning, business restructuring, financial modelling and transfer pricing. The two other partners are Henri Becker and Hannu-Tapani Leppänen. As of June 1 2016, Suvi Vänskä joined the team as a senior associate.
The team invests heavily in developing innovative solutions and approaches to revolutionise the way advisory services are provided. This year, the firm won various new clients and engaged in various high-profile cases involving challenging cross-border tax matters. The team was praised by clients for its quality services and was highly recommended.
Established in June 2015, Bird & Bird's Finnish tax practice is headed by Sami Tuominen. The team consists of four professionals: Tuominen, Anna Shumskaya, Anna Soininen and Mikko Laapas.
The fully-integrated team provides a full suite of tax advisory services, and benefits from the network of more than 60 experts across the globe to provide an extensive international offering. The Finnish team's combination of deep local knowledge, profound sector understanding and commitment to its clients, is what makes them stand out said Tuominen.
The team was praised by clients for its thorough work and high quality services. Tuominen especially came recommended for his general tax and succession planning expertise and the team's service-minded attitude.
Borenius, Taxand Finland's head of tax, Janne Juusela, specialises in litigation, transfer pricing and M&A. He is the sole partner of the practice and works closely with the nine other professionals in the practice, assisting clients with a full range of tax services. The team has expertise in M&A, tax disputes (particularly high-end litigation), international tax and transfer pricing.
This year, the team expanded with two new practitioners: transfer pricing senior associate, and head of transfer pricing Markku Renko, who previously worked at Alder & Sound, and associate Turo Lehtonen, a former tax auditor with the Finnish tax administration.
Other significant specialists in the practice include Einari Karhu, who specialises in international tax and litigation, Mikko Alakare, who has expertise in M&A, international tax and VAT, and Jonna Yli-Äyhö, who focuses on domestic and international income taxation and M&A tax.
The firm was highly recommended by its clients and one, Vesa Karvonen, said: "The firm has the best tax team apart from the Big 4 in Finland; the best compared to any other law firm. They are respected among the authorities and have good working relationship with the administrative courts. If you want to have the best available tax advice from a law firm in Finland, Borenius is the best service provider."
The tax and transfer pricing team at Castrén & Snellman is headed by Sari Laaksonen, who has more than 20 years of experience in tax and is a lecturer on the subjects of corporate taxation, corporate law and M&A.
The team of two partners and nine professionals covers all areas of corporate taxation, including VAT, M&A, due diligence, transfer pricing, tax inheritance and litigation on advance ruling procedures. Counsel Leena Romppainen is another key member of the team and has more than 20 years of experience in tax and M&A. She has been involved in client assignments both from cross-border and domestic aspects, especially in the areas of M&A, real estate and financing transactions.
The firm is recommended by clients for its professional service. One client said: "They are true professionals with a wealth of knowledge about Finnish taxation laws and regulations as well as tax authority practise and jurisprudence."
Tomi Karsio heads the tax and legal practices at Deloitte. He has 15 years of experience in domestic and cross-border corporate income tax and extensive experience with M&A, structuring and planning. The firm offers a wide portfolio of multinational clients a full range of services, such as business tax, international tax, tax management and consulting, tax M&A, and indirect tax and private company services. Key industries for the firm include consumer, financial services, energy and resources, manufacturing, life sciences and healthcare, real estate and technology, media and telecommunications (TMT).
Other significant members of the practice include Outi Ukkola, transfer pricing specialist, Lari Hintvonen and Pia Aalto, both corporate tax partners. Timo Sneck, specialises in indirect tax, customs and global trade, Jani Hirvonen, specialises in private tax and legal services, and directors Veera Campbell and Harri Huikuri.
DLA Piper's tax practice was established in March 2016 when Jaakko Klemettilä joined the firm. As an experienced tax expert, with 15 years of tax knowledge working at the Finnish tax administration, Big 4 firms, and a large public company, the new firm offers a range of services with M&A taxation as one of the key areas.
The firm benefits from the global DLA Piper network of more than 300 tax lawyers and economists across Europe, Asia-Pacific and the Americas. The network allows the team to provide comprehensive advice, anticipate potential changes in domestic and international tax legislation, giving consistent tax structuring advice and monitoring existing tax structures in order to avoid tax and reputational risk to global companies
Accounting firm EY Finland aims to provide clients with a service offering focused on quality, connectivity, responsiveness and insight. The tax team consists of nine partners and 125 dedicated professionals and is headed by Kari Pasanen, who is also the head of global compliance services in the Nordics. He joined the firm in 2006 and focuses on international tax, corporate tax, cross-border mergers and transfer pricing. The team offers the complete range of tax services, as well as legal services that complement the tax practice.
The practice, located in Helsinki, was in May 2016 named as the most attractive employer among Big 4 companies by students.
The tax practice at the Finnish law firm Hannes Snellman is led by Ossi Haapaniemi. He is also the chairman of the tax working group of the Finnish Bar Association and member of the board of the Finnish Tax Advisers' Association. His field of expertise is public and private M&A, capital markets, financial instruments, incentive schemes, EU tax law and tax litigation.
The dedicated team consists of seven professionals, including three partners, and recently appointed associate Matleena Pälve, who came from EY. She focuses on corporate and international tax and assists clients in tax litigation. Another significant partner is Heikki Vesikansa, who is a member of the legal committee of the Finnish Venture Capital Association.
The key focus of the firm is M&A and transaction tax advice as well as complex tax disputes. The practitioners cover all industries and is known as a transaction firm with excellent tax structuring capacity. This year, the firm worked on a €42.7 million ($47.6 million) deal, Alma Media's public tender offer for Talentum Oyj, including cash and share components causing specific tax related considerations.
Timo Torkkel heads the tax department of KPMG, consisting of more than 850 professionals in 22 locations. The team provides a range of multinational enterprises, medium-sized businesses and high net-worth individuals with audit, tax and advisory services. The accounting firm specialises in VAT, corporate and personal taxation, accounting and tax declaration. The advisory service offering includes development of supply chain and operation, and risk management and restructuring.
The team works across various industries, with emphasis on sectors such as public administration, banking and financial services, capital investment, consumer products and industrial equipment.
Krogerus is a large corporate law firm that focuses on transactional, dispute resolution and regulatory matters, particularly within the energy, finance, food and beverage, heathcare, real estate, and TMT sectors. The tax team is led by partners Antti Lehtimaja and Marko Vuori. Lehtimaja advises clients on all tax matters related to M&A, incentive schemes, financing instruments, investment funds and tax litigation. He has previous knowledge from both the private and public sector and has worked as a corporate tax specialist in the Finnish tax administration. Vuori represents clients in financing, M&A and other corporate structuring matters.
The tax department provides services both as part of an integrated legal service and on a standalone basis. Direct and indirect taxation, litigation and strategic tax planning advice is on offer as part of its full suite of services.
Petri Seppälä has been the head of the PwC tax practice since 2011 and has close to 20 years of experience providing clients with consultancy services and managing client portfolios. He is a former director at Deloitte and was a tax inspector before working for Big 4 firms. Because of his extensive experience and knowledge, Seppälä has beneficial insight to aid the firm's relationship with the Finnish tax authorities. The team offers a full range of services and advises on advance pricing agreements (APAs), mutual agreement procedures (MAPs) and audit support, and closely monitors changing tax legislation and practices on behalf of clients. Staple areas of work include corporate income tax, global tax compliance, human resource services, M&A and indirect tax.
Partner Mika Ohtonen leads Roschier's tax and structuring team of nine other dedicated professionals with a wealth of experience. The practice focuses on tax planning for M&A, restructures and disputes. The team provides clients with various tax services including structuring, M&A, private equity transactions and company restructurings and tender offers. The team is also regularly involved in overall tax planning related to changes in business models, transfer pricing, inventive schemes and transaction related VAT.
The team was involved in tax dispute before the Administrative Court of Helsinki, representing a company in regards its tax residency under the applicable double tax treaty. The firm's winning argument was built on an in-depth analysis of the regulation and the relation of the domestic tax legislation, the double tax treaty and the principles of the EU tax law as well as the applicability of the anti-avoidance provision.