Stefan Stellato
Stefan Stellato
Stefan advises clients in a broad range of tax matters. His practice is mainly focused on private clients, family investment companies, generation shifts, incentives and insurance products – often with an international angle. He is also involved in transactional work and taxation of cryptoassets.
In addition to his legal degree, he holds a Master of Science (Economics and Business Administration) degree from Hanken School of Economics.
References
Parties
Accel-KKR, Aico Group, Juuri Partners
Transaction
Accel-KKR’s majority equity investment in Aico Group
Deal Value
Value not public
Role
Counsel to Accel-KKR, a global technology-focused investment firm
Counsel in a Supreme Administrative Court Yearbook case on taxation of dividend paid on merger consideration shares.
Parties
A consortium consisting of Security Trading, Fennogens Investments, Corbis, and Bain Capital (buyer), Caverion Oyj (Target)
Transaction
Counsel to the offeror consortium consisting of Security Trading, Fennogens Investments, Corbis, and Bain Capital in the recommended public cash tender offer for all shares in Caverion Oyj.
Deal value
EUR 955 million
Role
Counsel to the offeror consortium consisting of Security Trading, Fennogens Investments, Corbis, and Bain Capital
Parties:
Duunitori Oy and its owners (seller), Intera Partners (buyer)
Transaction:
Counsel to Duunitori Oy and its owners in the sale of majority of Duunitori’s share capital to Intera Partners
Deal Value:
Value not public
Role:
Counsel to Duunitori Oy
Parties:
Esperi Care (target), Danske Bank, SEB, and Ilmarinen (majority owners), Triton (buyer)
Transaction:
Counsel to Esperi Care and its majority owners Danske Bank, SEB, and Ilmarinen in the acquisition of the majority of Esperi Care’s shares by Triton Smaller Mid Cap Fund II advised by Triton.
Deal Value:
Value not public.
Role:
Counsel to Esperi Care and its majority owners
Counsel to Finnish Customs in the public procurement of bitcoin brokerage services. The assignment is related to the Finnish Government’s decision to sell the Bitcoins and other cryptocurrencies seized by Finnish Customs and allocate a significant share of the additional revenue to support Ukraine in the current war.
Parties
Viking Line Abp
Transaction
Counsel to Viking Line Abp on its EUR 51.8 million issue of new shares with pre-emptive rights for existing shareholders.
Deal Value
EUR 51.8 million
Role
Counsel to Viking Line Abp
Counsel to a Finnish private equity fund in a Supreme Administrative Court Yearbook case confirming the correct application of equity ratio exemption in interest deduction limitations.
Parties
Virala Acquisition Company Plc, Purmo Group Ltd
Transaction
Virala Acquisition Company Plc's merger with Purmo Group Ltd.
Deal Value
EUR 685 million
Role
Counsel to Virala Acquisition Company Plc
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 tax payer in Supreme Administrative Court Yearbook case confirming US GAAP as acceptable basis for transfer pricing.
Parties
Ahlstrom-Munksjö Oyj (target), a consortium consisting of Ahlström Capital, Bain Capital Private Equity, Viknum and Belgrano Inversiones (buyer)
Transaction
Recommended public cash tender offer for all shares in Ahlstrom-Munksjö Oyj by Spa Holdings 3 Oy
Deal value
Approximately EUR 2.1 billion
Role
Counsel to the consortium
Parties
Optomed Plc
Transaction
Optomed’s IPO and listing on the Nasdaq Helsinki stock exchange
Deal Value
The offering by the company and its shareholders amounted to approximately EUR 44 million
Role
Counsel to Optomed Plc
Counsel in Supreme Administrative Court case confirming equal treatment of a Swedish real estate investor in Finnish taxation
Parties
Outotec Oyj, Metso Corporation
Transaction
The combination of Outotec and Metso Minerals through a demerger
Deal Value
EUR 3.9 billion (illustrative combined sales)
Role
Counsel to Outotec Oyj
Parties
Tieto Corporation, EVRY ASA
Transaction
The combination of Tieto and EVRY through a cross-border merger
Deal Value
Value not public
Role
Counsel to EVRY ASA
Counsel to CEMEX in its sale of assets in the Baltics and Nordics to the German building materials group SCHWENK, 2019
Parties
Cramo Plc, Adapteo Plc
Transaction
Cramo’s partial demerger and listing of Adapteo on Nasdaq Stockholm
Deal Value
SEK 5.5 billion
Role
Counsel to Cramo Plc and Adapteo Plc
Parties
Precast Holding Oy (Buyer), Elematic HoldCo Oy (Seller), Elematic Oyj (Target), Nordic Trustee (as bonds trustee appointed by Elematic’s
Transaction
Restructuring of ownership and financing structure of Elematic Oyj
Deal Value
Value not public
Role
Counsel to Nordic Trustee
Parties
Qingdao Sifang SRI Intellectual Technology Co. Ltd. (Buyer), Beneq Oy and its shareholders (Sellers), Beneq Oy (Target)
Transaction
The sale of Beneq Oy to Qingdao Sifang SRI Intellectual Technology Co. Ltd.
Deal Value
Value not public
Role
Counsel to Beneq Oy and its shareholders
Counsel to a client receiving confirmation from the Supreme Administrative Court that despite domestic tax law provisions the treaty dividend participation exemption prevents Finland from taxing a capital repayment from paid-in capital by a US subsidiary.
Parties
Lemminkäinen Corporation and YIT Corporation
Transaction
The combination of Lemminkäinen Corporation and YIT Corporation through a statutory merger
Deal Value
EUR 771 million
Role
Counsel to Lemminkäinen
Parties
Ahlstrom Oyj, Munksjö Oyj
Transaction
The combination of Ahlstrom and Munksjö through a merger
Deal Value
Approx. EUR 1,2 billion
Role
Lead counsel to Ahlstrom
Rankings
- "Stefan Stellato has deep knowledge of international tax matters and provides very logical and clear advice.", Tax, Legal 500, 2024
- "Stefan Stellato is also one to watch.", Tax, Legal 500, 2023
- Financial Times Innovative Lawyers Awards 2023: Highly Commended. “The firm helped Finnish customs authorities to conduct a public auction of bitcoin, then worth about €70mn, seized from illegal drug dealers. Funds of about $47mn raised by sale in 2022 were donated to the Ukrainian government.”
Memberships and Positions of Trust
- Board member (deputy) of the Law Society of Finland (Juridiska Föreningen i Finland r.f.), 2023-
- Member of International Fiscal Association (IFA)
- Member of the Finnish Bar Association
- National reporter for Finland of the International Bar Association (IBA), 2020-2022
- Treasurer of the Law Society of Finland (Juridiska Föreningen i Finland r.f.), 2019-2022
Publications
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 12th edition, 2023
- Co-author of the article The Court of Justice of the European Union rules that Finnish tax rules discriminate against foreign company form investment funds, MNE Tax, 2022
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 11th edition, 2022
- Co-author of the article Finnish court rules on arm’s length range and transfer pricing adjustment point, MNE Tax, 2021
- Co-author of the article Finnish court accepts US GAAP as basis for transfer pricing in landmark ruling, MNE Tax, 2021
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 10th edition, 2021
- Author of a book review on crypto taxation (available only in Finnish), Verotus-lehti, 2021
- Co-author of the Finnish Chapter in the third edition of The Corporate Tax Planning Law Review, 2021
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 9th edition, 2020
- Co-author of the Finnish Chapter in the second edition of The Corporate Tax Planning Law Review, 2020
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 8th edition, 2019
- Co-author of the Finnish Chapter in the inaugural edition of The Corporate Tax Planning Law Review, 2019
- Uraauurtava ratkaisu kansallisen ylimmän tuomioistuimen velvollisuudesta tehdä ennakkoratkaisupyyntö EUT:lle - Groundbreaking Ruling on a National Court’s Obligation to Refer a Question to the ECJ (available only in Finnish), Edilex, 2018
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 7th edition, 2018
- Verolain aukkokohdan täyttäminen – EVL 18 a §:n 3 momentin tasetestin soveltaminen pääomarahastorakenteissa | Filling a Legislative Gap – Application of the Finnish Equity Ratio exemption from interest barrier rule in Private Equity Fund Structures (available only in Finnish) Defensor Legis, 2018
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 6th edition, 2017
- Co-author of the Finland Chapter in The Private Wealth & Private Client Review, 5th edition, 2016
Education and Professional Background
- Managing Associate, Hannes Snellman, 2022
- Senior Associate, Hannes Snellman, 2021
- Master of Science (Economics and Business Administration), Hanken School of Economics, 2017
- Associate Lawyer, Hannes Snellman, 2016
- Master of Laws, University of Helsinki, 2016
- Associate Trainee, Hannes Snellman, 2016
- Maurice A. Deane School of Law at Hofstra University, New York, 2015
- Trainee, Reims & Co, 2014-2015