Finland

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Transfer pricing
Alder & Sound

Alder & Sound is a boutique firm, founded in 2010, that offers legal, transfer pricing, tax and financial advisory services to a variety of clients including multinationals and SME's. The firm is best known for its transfer pricing advice, with a team of analysists capable of conducting all benchmarking, value chain analysis and arm's-length analysis. It also advises firms on the planning, design and implementation of transfer pricing policy, as well as defending clients in transfer pricing audits and disputes. The transfer pricing services team is led by Henri Becker and includes managing partner Petteri Rapo. 

The team recently assisted a multinational services business with a rapid optimisation of their business model, necessary for an imminent cross-border expansion, in order to streamline the internal operating model while ensuring compliance. It was chosen by the Finnish tax authorities to organise and conduct the first CDB discussion in January 2019, involving the new structure for opening discussions between two or more jurisdictions with the taxpayer to determine specific cross-border taxation issues before implementation.

Client feedback

“The company takes very good care of the overall documentation process and the possible implementation of changes in legal requirements in different countries in the documentation. The company is excellent in adapting its own operations to the customer’s way of working, by presenting constructive proposals for improvement (both in the customer and company’s way of working) and concrete ways to implement improvements. If necessary, the team produces results with very short notice. The company has a well-established network of partners around the world that they offer to their customers when needed. However, it is also small, so the absence of one person is visible to the customer. During unexpected absences, they take care of the most urgent and routine tasks, but more demanding tasks may be delayed. In such delays, communicating with the customer may be occasionally incomplete, even if communication is handled ex post.”

“I have worked with A&S for more than eight years, and will continue working as a main partner for transfer pricing matters. They are highly experienced and their approach is customer focused.”

“One of the strengths of the firm is that it has a good international network. It can provide support around a large range of tax issues, from transfer pricing to group restructuring. It is reliable and solution oriented, client focused, and provides partner-level involvement through all engagements, not just at key stakeholder meetings. At the same time, on transactions Alder & Sound would benefit from partnering with a transaction-focused law firm so it could act as a one-stop-shop for both tax and deal execution.”

Bird & Bird

The transfer pricing practice of Brid & Bird Finland advises its clients on the transfer pricing aspects of cross border M&A deals, as well as advising insurance agencies on the transfer pricing issues regarding warranty and indemnity insurance issued in transactions. Senior tax specialist Antti Paloniemi is the key advisor on these projects.

Borenius

Borenius focuses its transactional practice on dispute resolution and representation before the Finnish courts, as well as representation in MAP discussions. The firm, through senior associate Sampo Viding, also offers transfer pricing documentation and business model implementation. 

The team recently obtained a favorable decision for Nokian Tyres in a Supreme Administrative Court case, following the authorities' €89.2 million reassessment for the years 2007-2010. The case concerned the business model implementation between the parent company and its subsidiaries, as well as whether the transfer pricing policy had been conducted within arm’s-length principles.

Client feedback  

“Very experienced group of tax practitioners, best in complicated tax disputes.

Deloitte

Transfer pricing continues to be one of the largest growth areas for Deloitte Finland. The firm has a number of Finnish and multinational clients for whom it conducts transfer pricing analysis, including value creation analysis and economic modeling. It also advises on the realignment of existing transfer pricing policy as well as the creation and implementation of new transfer pricing policies. The large transfer pricing team includes partners Jari Ahonen and Hanna Viilo.

EY

The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.

KPMG

Client feedback

“Experienced team and extensive market exposure.”

PwC

Client feedback

“Strong market position overall.”

“PwC has one of the largest tax departments in Finland, in terms of revenue and personnel.”

Roschier

Roschier uses its transfer pricing expertise to assist clients in cross-border acquisitions for both transfer pricing issues pertaining to the transaction itself and with transfer pricing documentation following the acquisition. The firm also deals with transfer pricing audits and disputes. Partner Mika Ohtonen deals with disputes and litigation while senior advisor Merja Raunio deals with the transfer pricing policy and structure.