20.9.2016

Preliminary Tax Rulings – Tax Disputes Avoidable through Proactive Planning

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Careful planning is often the key to a successful arrangement, and it is possible to get definitive answers to questions that are open to interpretation through a ruling of the Finnish Tax Administration. The Tax Administration has recently focused on improving cooperation with its customers and has encouraged companies to actively apply for written preliminary rulings and even engage in preliminary discussions concerning more challenging arrangements.

We have assisted Finnair and Municipality Finance, among others, in arrangements that involved significant income tax questions, which we resolved by applying for preliminary rulings. In the following, we describe a few of our recent case references involving preliminary rulings.

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Tax Disputes – A Key Part of Corporate Financial Administration

Disagreements that arise in the tax assessment and in tax audits often lead to lengthy appeal processes that sap time and resources from a company’s management and financial department. We advocate a pre-emptive approach to avoid problems through careful analysis of tax issues, diligent reporting and smooth communication with the tax authorities. Should you nevertheless find yourself facing a tax dispute, whether domestic or international in nature, you will be able to rely on our renowned dispute resolution team to defend your interests. We will also provide you with the best possible assistance in handling tax complaint processes if your company is subject to a tax audit or if the Finnish Tax Administration intervenes in any arrangements at a later date.

Municipality of Tuusula – Data centre project

We are assisting the Municipality of Tuusula in the sale of land to funds managed by Blackstone, a global asset management company, for a data centre project. Currently, a preliminary agreement has been signed for the sale of the approximately 16.7 hectare site in Jokela, Tuusula. In October 2025, the Municipal Council of Tuusula approved zoning amendments that enable the construction of a data centre campus in the Vallunlenkki zoning area. The preliminary agreement on the sale of the land and the approval of the zoning are the first steps in a process that would upon its implementation constitute a significant investment that supports employment and economic growth in Tuusula and its surroundings. The next phase, the environmental impact assessment, is planned to commence in early 2026. Blackstone owns QTS, one of the worlds’s fastest growing data centre platforms with more than 82 data centres in operation or under development across Europe and the United States.

OP-Public Services Real Estate Fund – Sale of seven preschool properties

We are assisting OP-Public Services Real Estate Fund in the sale of seven preschool properties to Kinland AS. The transaction value is approximately EUR 24 million, and the majority of the properties are located in the Greater Helsinki area. The portfolio comprises high-quality assets with EPC ratings of A or B, with most properties achieving the highest rating of A. The properties are leased to one of the sector’s leading private operators under lease agreements with a weighted average unexpired lease term of approximately 10 years. The transaction is expected to close on 18 December 2025.

CapMan Growth – Investment in restaurant chain Factory

We are assisting CapMan Growth in making a significant investment in Factory, a Finnish restaurant chain known for its high-quality homemade meals and excellent value for money. The investment supports Factory’s ambitious growth strategy to expand nationwide and strengthen its presence also in shopping centres. Industry veteran Aku Vikström also joins as a co-investor and member of the board to support the company. Factory is a restaurant chain that specialises in high-quality homemade meals. In addition to buffet offerings, Factory provides catering services for meetings and events. All dishes are prepared in Factory’s own restaurant kitchens by the restaurants’ own chefs, and the menu focuses on diverse, high-quality home cooking. The company currently operates 22 restaurants in Southern Finland and employs around 200 people. CapMan Growth is a leading Finnish growth investor that makes significant investments in entrepreneur-led growth companies with turnover of €10–200 million. CapMan Growth is part of CapMan, which is a leading Nordic private equity investor engaged in active value creation work. CapMan has been listed on the Helsinki Stock Exchange since 2001.

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