5.5.2024

Wealthy private individual Tax dispute

We assisted a very wealthy private individual in a large-scale tax dispute that concerned expatriation.

The tax authorities reviewed the taxation of the private individual through a subsequent assessment, arguing that the final preliminary ruling on the individual’s expatriation could be disregarded as subsequent assessment showed that some of the future plans included in the application had not been realised. The reassessment of taxation carried out by the Tax Administration led to significant residual taxes for the individual. A key issue in the tax dispute was whether genuine expatriation could be subject to the tax avoidance regime.

Latest references

We assisted a prominent family-owned company in the incorporation of their business. Our clients appreciated the ability to discuss various possibilities with us, after which we conducted a detailed analysis of the options that seemed most viable. There were various factors to consider, ranging from corporate governance to international taxation, due to which the most attractive options from a Finnish tax perspective turned out to be less feasible in the overall analysis. In addition to our expertise, our clients were very satisfied with the comprehensive service they received beyond tax issues, delivered in a smooth and efficient manner through a single point of contact.
Case published 20.9.2024
We drafted a full set of shareholders’ agreements for family-owned associated companies to align and record the family members’ objectives within the companies. Developing and revising an ownership strategy usually requires extensive discussions at the ownership level. These discussions must identify the future prospects each owner sees and the owners’ capacity to commit to a coherent strategy. The discussions may involve difficult issues, but their resolution is essential for long-term ownership. We assisted the family in codifying the ownership strategy of associated companies into shareholders’ agreements. During this revision work, the owners received a useful snapshot of the drivers propelling the business forward.
Case published 10.9.2024
We assisted the shareholders of a contentious estate on legal issues relating to inheritance and succession, as well as on the tax aspects of the distribution of the estate. Our advice covered a comprehensive set of legal issues, combining substantive inheritance law expertise with maintaining active contact with the heirs, facilitating negotiations between them, providing inheritance tax planning and handling various processes relating to the distribution of the estate. The clients appreciated that we actively advanced the matter and proactively highlighted different points of view at different stages of the process. It was important for the clients to understand what their options were and to know what to expect at each stage of the process.
Case published 13.8.2024
We assisted a family-owned company in planning and implementing the transition of the business to the next generation. The generational change was implemented through several M&A transactions by restructuring the family members’ holdings into logical and distinct corporate entities. The client appreciated our highly professional service, where we reviewed the main aspects of the different options before choosing the best course of action and took the lead in advancing the project. We applied for pre-emptive guidance from the Finnish Tax Administration on key tax consequences and collaborated with our network of international advisors to assist with international tax issues. 
Case published 14.6.2024