Hannes Snellman’s tax practice offers high-end corporate tax advice, VAT and other indirect tax advice, tax litigation assistance, and private wealth planning. The team continuously provides tax advice on major public and private M&A transactions, capital markets transactions, financial instruments, incentive schemes, as well as formation of private equity and other types of investment funds. Within private wealth planning, the team assists clients in succession tax planning, relocation tax advice, and investment structures. Hannes Snellman regularly represents clients to defend their tax positions in demanding tax litigation and often handles cases which become case law precedents for Finnish tax law. Our tax practitioners provide high-quality tax solutions in an increasingly complex field of law, and they have a strong international reputation for providing pragmatic and effective tax advice.
Counsel in the Central Tax Board’s advance ruling proceeding overruling the Tax Authority’s public guidance on peer-to-peer rentals (such as Airbnb). Pursuant to the advance ruling decision (KVL 30/2020), short-term renting does not break the requirement of two years of continuous living to which the Finnish capital gain exemption on residential properties is subject.
The advance ruling can still be appealed to the Supreme Administrative Court by the Tax Recipients’ Legal Services Unit.
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
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
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
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.
Ilmarinen Mutual Pension Insurance Company, Kesko Corporation, Kesko Pension Fund, Kruunuvuoren Satama Oy
Transaction
A series of transactions, whereby Ilmarinen, Kesko, and Kesko Pension Fund, among other things, dissolve their joint ownership of Kruunuvuoren Satama and Ilmarinen acquires all 3,438,885 Kesko A shares held by Kruunuvuoren Satama.
Deal Value
EUR 164 million
Role
Counsel to Ilmarinen Mutual Pension Insurance Company, Kesko Corporation, Kesko Pension Fund, and Kruunuvuoren Satama Oy
Funds managed by Sentica Partners Oy (Buyer), Mikael Swanljung and his family (Sellers), Picnic Finland Oy, Europicnic Oy and La Torrefazione Oy (Targets)
Transaction
Sentica Partners’ acquisition of majority ownership in Picnic Company Group from Mikael Swanljung and his family
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.
Areim Fund III (Buyer), Avant Capital Partners, Varma Mutual Pension Insurance Company, EPISO 4 fund (Sellers)
Transaction
Areim Fund's acquisition of a portfolio of eight office properties from Avant Capital Partners, Varma Mutual Pension Insurance Company and EPISO 4 fund advised by Tristan Capital Partners
CVC Capital Partners, LocalTapiola, Varma, Ilmarinen, Mehiläinen management (Buyers), Mehiläinen Oy (Target), Kohlberg Kravis Roberts & Co. L.P., Triton Partners (Sellers)
Transaction
LocalTapiola's co-investment with CVC Capital Partners, Varma and Ilmarinen to Mehiläinen Oy, a leading Finnish private health- and social care provider
Handled pilot cases concerning the tax treatment of debt pushdown in the Supreme Administrative Court.
Counsel to a tax payer in a court proceeding which confirmed that earn out payments cannot be taxed as salary income subject to highest progressive tax rates.
Counsel to several landlords defeating Finnish Tax Authorities’ attempt to deny VAT deductions on the basis of tenant’s bankruptcy.
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.
Santander Consumer Finance Oy, SFC Rahoituspalvelut Kimi VI DAC
Transaction
Issue of EUR 634,700,000 Class A Notes and EUR 64,800,000 Class B Notes by SFC Rahoituspalvelut Kimi VI DAC secured by a portfolio of hire purchase agreements made by Santander Consumer Finance Oy
Vaaka Partners (Buyer), management and minority shareholders (Sellers), Smoothie Heaven Oy (Target)
Transaction
Vaaka Partners acquired majority of shares in Smoothie Heaven Oy, a juice and smoothie bar company known as Jungle Juice Bar, from management and minority shareholders
J.P. Morgan Asset Management fund (Seller), Alma Property Partners I AB (Buyer)
Transaction
The disposal of four office properties in the Keilaniemi business district of Espoo, Finland by a J.P. Morgan Asset Management fund to Alma Property Partners I AB
A transaction creating a JV with Neste and Borealis to build a new combined heat and power plant and produce and supply steam and other utilities to Neste's refinery and Borealis' petrochemical plant in Porvoo, Finland
Faron Pharmaceuticals Ltd's IPO and listing on the AIM market of the London Stock Exchange as well as the preceding fundraising of approx. GBP 10 million
Summit Partners (Buyer), Retail Logistics Excellence - RELEX Oy and certain shareholders of RELEX (Seller), Retail Logistics Excellence - RELEX Oy (Target)
Transaction
Summit Partners' acquisition of a EUR 20 million minority stake in RELEX, a Finnish provider of supply chain software solutions for retailers
Counsel to Henri Juva in the sale of a majority of shares in Quattro Mikenti Group Oy to Adelis Equity Partners Fund I AB by Henri Juva and other sellers.
Represented P Oy in a state aid case (C-6/12) related to the selectivity in the Finnish special permission procedure concerning the utilisation of tax losses following a significant change in the ownership of a Finnish company. In the case, the Finnish Supreme Administrative Court had requested preliminary ruling from the European Court of Justice and as a result, P Oy received the permission to utilise the tax losses.
Prevailed in a published landmark Supreme Administrative Court case where the Supreme Administrative Court annulled res judicata CFC decisions (including its own) because they were in conflict with Cadbury Schweppes (C-196/04) ECJ decision. In 2002, the Supreme Administrative Court had neglected its duty to refer the case to the ECJ.
Counsel to Swedish foundations in dividend withholding tax reclaim cases where the Supreme Administrative Court decided, based on the EU principles, that non-residents should also receive interest for the amounts paid back. The Finnish legislation was later amended to correct the situation.
Prevailed in a case recently published in the Supreme Administrative Court Yearbook concerning the question of whether the tax surcharge should be calculated on the basis of the gross amount or the net amount of the mistake.
Prevailed in a published landmark Supreme Administrative Court case concerning the allocation of income from employee options in cross-border situations. Due to the decision, the Finnish system was changed to better match the OECD principles.
Counsel to Raisio plc in a case against the Finnish Tax Authorities in order to have the profit of MEUR 220 generated from the divestment of Raisio plc’s chemicals business declared tax exempt. The Finnish Supreme Administrative Court decided the case in favour of Raisio plc, thereby “saving” them some MEUR 80.
Counsel in legal proceedings before the Finnish Supreme Administrative Court leading to a ruling whereby Finnish tax authorities are not entitled to raise back taxes from companies by re-characterising legal transactions without relevant mandate given by Finnish domestic tax law.
Counsel in a Central Tax Board case resolving the correct consolidation level indicated in the safe haven rule of the new Finnish interest deduction limitations (earnings stripping).
Counsel in legal proceedings before the Helsinki Administrative Court confirming an earlier Supreme Administrative Court decision that transfer taxes are not payable on the termination of share options.
Counsel to several tax payers successfully claiming a refund for unlawfully imposed transfer tax on issue of employee stock options.
Counsel to a client receiving a confirmation from the Finnish Supreme Administrative Court that an effective redemption clause is to be taken into account when valuing shares for gift tax purposes.
'Ranked Tier 1 in Transactional tax and Tax controversy - Finland.'
'Tier 2 in General corporate tax and Indirect tax - Finland.'
Ranked Band 1 in Finland
Interviewees describe it as a "solid firm in the market,"and note that "they have one of the biggest tax practices."
One market insider says that "it is one of the leading firms in Finland," adding: "They are always timely, professional and everything is done in a non-bureaucratic manner."
'Ranked Tier 1 in Tax, Finland'
'A client highlights the practice's commerciality, noting:"They understand the underlying issues and impacts and provide very valuable insights from the tax side, and they understand the business side, too."'
'Another client comments on the team's ability to advise on cross-border matters, saying: "They understand what international clients need and they have excellent language and negotiation skills."'
'Clients report that the team "works very effectively and can provide high-quality statements in a short time period."
‘Another client enthuses that "whenever we needed their help, they were there right away," and adds that "the whole impression of the firm and their expertise is really good."'
‘Ranked tier 1 in transactional tax - Finland.’
'One client said: "I was very pleased how Hannes Snellman served our business during the acquisition process. They were very professional and their deep knowledge of M&A helped me a lot during the process."'
'One client notes that "they are strong performers, very patient, professional and proactive."'
'The team receives praise from interviewees for its "excellent quality and strong resources."'
'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.'
'Outstanding tax team advising on both national and cross-border tax matters. Areas of expertise include the tax aspects in public M&A transactions, financial instruments, private equity deals and venture capital. Scope of expertise also extends to corporate tax issues, EU tax law and tax litigation.'
‘Hannes Snellman specialises in tax planning and structuring public and private M&A transactions. Heikki Vesikansa joined from KPMG to head the transactional structuring practice. He advises clients in tax structuring of investments, divestments and joint ventures.’