7.2.2020

New Act on Reporting Obligation for Transactions

Finnish Parliament recently enacted a new act regarding reportable transactions in the field of taxation (in Finnish ‘Laki raportoitavista järjestelyistä verotuksen alalla’). The purpose of the act is to implement the European Union Directive on the mandatory disclosure and exchange of cross-border tax arrangements, generally referred to as DAC6.

The act requires intermediaries or taxpayers to report qualifying cross-border arrangements to local tax authorities. The reporting obligation applies only to specific types of transactions that are deemed to involve a risk of tax avoidance or tax abuse. The Finnish act includes certain exceptions governing attorneys-at-law.

Reportable arrangements generally include arrangements that were initiated as of 25 June 2018, i.e. the reporting obligation will be retroactive. The reporting obligation for transactions initiated between 25 June 2018 and 30 June 2020 needs to be fulfilled by end of August 2020.

The Finnish Tax Administration is expected to provide written guidance regarding the actual application of the act during the spring of 2020.

Our tax advisors will be happy to provide further details concerning the reporting obligation.

Latest references

We acted as Finnish law legal adviser to the lenders and the export credit agencies in connection with the EUR 514.4 million green project financing for the development and construction of Easpring Finland New Materials Oy’s cathode active material (CAM) manufacturing plant in Kotka, Finland. The borrower, Easpring Finland New Materials Oy, is a joint venture owned by Beijing Easpring Material Technology, Finnish Minerals Group and LG Energy Solution. The financing was provided by six international commercial banks, with Société Générale acting as financial adviser and mandated lead arranger together with Natixis as co-mandated lead arranger, and DNB, ICBC, ING and Standard Chartered participating as lenders, with support from the export credit agencies Finnvera and Sinosure. The project represents a significant milestone for Finland and the European battery value chain by strengthening Europe’s domestic supply of cathode active materials, a key component in lithium-ion batteries for electric vehicles and energy storage applications. Once the first phase of the project is operational, the Kotka facility is expected to produce approximately 60,000 tonnes of cathode active material annually, making it one of the largest CAM production plants in Europe and supplying leading battery manufacturers across Europe. 
Case published 21.7.2026
We acted as Finnish legal advisor to Delta Capacity in connection with its acquisition of the ready-to-build Karppio battery energy storage system (BESS) project from Helios Nordic Energy. The acquisition was made and the project will be implemented together with Strioga Family Foundation. The Karppio BESS project is located in Teuva, Finland, and has a capacity of 125 MW / 300 MWh. Delta Capacity will lead the remaining development of the project through to commissioning, planned for 2027, and will serve as long-term asset manager. Delta Capacity is a Swiss-based developer of utility scale battery storage systems. The acquisition adds to Delta Capacity’s growing Nordic portfolio. 
Case published 20.7.2026
We advised Swedbank AB (publ) on the refinancing of a large Finnish retail real estate portfolio owned by Trophi’s Finnish subsidiaries. Trophi is the leading Nordic real estate company focusing on grocery anchored retail properties, with 278 properties across Sweden and Finland. Finland is a market that continues to develop and is also strategically important for Trophi, accounting for approximately 30% of Trophi’s letting and property value.
Case published 17.7.2026
We are acting as Finnish legal advisor to HANZA in connection with its acquisition of Fortaco Finland’s heavy mechanics and assembly business. The transaction is structured as a combined asset and share acquisition and includes Fortaco Finland’s heavy mechanics and assembly operations in Finland, as well as shares in two Estonian and two Polish subsidiaries. The transaction is expected to close during the fourth quarter of 2026, subject to customary closing conditions, including regulatory approvals. Founded in 2008, HANZA is a Swedish mechanical engineering and electronics contract manufacturing company listed on the Nasdaq Stockholm main list. HANZA has approximately 5,000 employees and annual sales of SEK 10 billion. We advise HANZA on this transaction in collaboration with the Swedish law firm Lindahl.
Case published 15.7.2026