Piia Ahonen

Hannes Snellman assisted the client in an advance ruling process to confirm that certain services acquired regarding the target investment were considered VAT exempt management services of special investment funds and that the client did not have to pay VAT under the reverse charge mechanism. The matter was important to the client, as in practice it may vary what kind of services are needed to be acquired when acting as a lead investor or co-investor joining an investment at a later stage. The services in question formed a sufficient bundle of services qualifying for the criteria of VAT exempt financial services necessary for the client to be able to make the investment decision and similar investments in a more efficient way in the future as well. The Finnish tax authorities’ first opinion was that the services were VATable, but Hannes Snellman’s VAT team was able to change the outcome during the advance ruling process. The ruling is now final.

Parties

Häggblom & Partners Ltd. and the sellers, UB Nordic Forest Fund II LP, United Bankers

Transaction

Counsel to Häggblom & Partners Ltd. and the sellers in the sale of UB Nordic Forest Fund II LP. The sale of approximately 33,000 hectares of forest properties and partnership interests in UB Nordic Forest Fund II LP, managed by United Bankers, was agreed upon with MEAG, an asset management company of the Munich Re Group acting on behalf of its group client. Upon completion, the buyer will pay a total purchase price of approximately EUR 166 million.

Deal Value

Approximately EUR 166 million

Role

Counsel to Häggblom & Partners Ltd. and the sellers

Counsel a real estate company in a case regarding the VAT deduction of real estate investments. The Finnish Tax Administration had not accepted the VAT deductions made by the company because it had found that the premises were used for both VAT taxable and VAT exempt activities. In the case, it was evaluated from the VAT perspective how the leasing area can be determined per floor of the building while also considering how the premises are described in the articles of association.

Assisted by Hannes Snellman's tax team, the company appealed the Tax Administration’s decision to the Administrative Court and was able to prove that the premises were mostly used for purposes entitling to a VAT deduction, wherefore the company had had the right to deduct the VAT of the costs related to these premises that were used for VATable purposes. The company won the case in the Administrative Court, after which Hannes Snellman assisted the company with the preparation of corrective VAT returns and the refund of VAT that had been groundlessly left unrefunded.

Parties:

YIT

Transaction:

Counsel to YIT in the disposal of its wind and solar business, comprising of 2.3 GW renewable energy projects and a team of 16 employees.

Deal value:

Value not public

Role:

Counsel to YIT

Parties

If Livförsäkring AB (Buyer), Mandatum Life (Seller)

Transaction

If Livförsäkring AB's acquisition of a life insurance portfolio from Mandatum Life

Deal Value

EUR 17.5 million

Role

Counsel to If Livförsäkring AB

Parties:

United Bankers’ UB Timberland Fund (AIF), Taaleri Forest Fund III LP

Transaction:

United Bankers’ UB Timberland Fund (AIF) agreed to acquire Taaleri Forest Fund III LP. The forests managed by Taaleri Forest Fund III comprise 19 forest properties covering in total a surface area of approximately 7,650 hectares of which more than 6,400 hectares is productive forest land.

Deal value: 

Value not public

Role:

Counsel to United Bankers’ UB Timberland Fund (AIF)

Parties 

Slättö Core Plus and PEAB

Transaction 

Hannes Snellman acted as counsel to Slättö in the formation of a joint venture with PEAB regarding investments into residential housing in Finland.

Deal Value 

Value not public

Role

Counsel to Slättö Core Plus

Parties

Tencent (Investor), Vitruvian Partners (Co-Investor), Enfuce Financial Services Oy (Target)

Transaction

Counsel to Tencent in its further investment in Enfuce Financial Services, a leading European Card-as-a-Service (CaaS) platform for modern card issuing and processing, in connection with a EUR 45 million Series C investment round

Deal Value

EUR 45 million

Role

Counsel to Tencent

Parties

Anora Group Plc (Altia Plc, Arcus ASA) and Galatea AB

Transaction

Required pre-closing divestment of Altia’s brands Skåne Akvavit, Hallands Fläder, and Brøndums and cognac brand Grönstedts (along with Arcus’s aquavit brand Akevitt Spesial and spirits brands S.P.R.T. and Dworek) to Galatea AB. The divestment to a suitable buyer was required by the Finnish, Norwegian, and Swedish competition authorities as a condition to their approval of the merger between Altia and Arcus to form Anora Group.

Deal value

Not public

Role

Lead counsel to Altia Plc (Anora Group Plc)

Parties 

Quadoro Investment GmbH, EKE-Construction Ltd.

Transaction 

Counsel to a fund managed by Quadoro Investment GmbH in an acquisition of an office property located in Espoo with a lettable area of approximately 4,200 square metres from the constructor EKE-Construction Ltd.

Deal Value 

Value not public

Role

Counsel to Quadoro Investment GmbH

Parties 

Quadoro Investment GmbH, YIT Construction Ltd.

Transaction 

Counsel to a fund managed by Quadoro Investment GmbH in an acquisition of a MEUR 32 office property located in Järvenpää with a lettable area of approximately 6,500 square metres from YIT Construction Ltd

Deal Value 

EUR 32 million

Role

Counsel to Quadoro Investment GmbH

Parties

Virala Acquisition Company Plc

Transaction

Hannes Snellman acted as legal counsel to Virala Acquisition Company Plc on its IPO and the listing of its Class C shares on the SPAC segment of the regulated market of Nasdaq Helsinki

Deal Value

EUR 107.5 million

Role

Counsel to Virala Acquisition Company Plc

Counsel to a taxpayer in the Supreme Administrative Court Yearbook case outlining VAT treatment of coworking services.

Parties

A fund managed by Quadoro Investment GmbH

Transaction

Acquisition of Hermia 5 and Hermia 6 office properties located in the Hermia Science Park in Tampere with a lettable area of approximately 30,000 square metres

Deal value

Value not public

Hannes role

Counsel to a fund managed by Quadoro Investment GmbH

Hannes team

Tapio Teräkivi, Heikki Vesikansa, Markus Bremer, Marjaana Martikainen, Jenni Parviainen, Piia Ahonen, Meeri Karlsson, Ella Rinne, Panu Vikberg, Linda Launonen, and Viivi Rousku.

Parties

City of Espoo, Kumppanuuskoulut Oy, YIT Oyj, Meridiam Investments II

Transaction

The City of Espoo signed a service agreement with Kumppanuuskoulut Oy on the implementation of five schools and three daycare centres

Deal Value

Approx. EUR 300 million

Role

Counsel to City of Espoo

Team

Rabbe Sittnikow, Jussi Ekonen, Janna Pihanurmi, Janne Veneranta, Roosa Väre, Markus Bremer, Maria Landtman, Samuli Pirinen, Heikki Vesikansa, Harri Vehviläinen, Piia Ahonen, Joakim Lavér

Parties 

DWS (buyer), Regenero (Seller)

Transaction

DWS's acquisition of the Accountor Tower, a 24,000 sq. m. office development in Keilaniemi, Espoo, from YIT and HGR Property Partners’ joint venture Regenero

Deal Value

Value not public

Role

Counsel to DWS

Counsel in Supreme Administrative Court case confirming real estate investor’s right to deduct VAT on transaction expenses

Counsel to a taxpayer receiving confirmation that a transfer of a business at an early stage qualifies as a transfer of a going concern for VAT purposes.

The Finnish Supreme Administrative Court issued a resolution concerning the VAT treatment of intermediary services to Finnish students aiming to study abroad in the U.S. Piia Ahonen successfully defended the client’s position through instances, and the resolution issued by the Supreme Administrative Court as a yearbook decision finally confirms that the client’s position is right and that the tax assessments were unlawful. The intermediary services are not subject to Finnish VAT due to the fact that the client acted as an intermediary between U.S. schools and Finnish students in relation to U.S.-based education and accommodation services that are not taxed in Finland.