Recent Cases
A&S plans and facilitates an internal training concerning permanent establishment issues for a Swiss listed company's personnel.
A&S advises an international service company with legal restructuring.
A&S performs a comparability search in respect to support a Finnish consumer company's Polish transfer pricing documentation.
A&S assists a Finnish listed company with implementation of a centralized business model.
A&S assists a Finnish law firm with ownership restructuring.
A&S advises a Finnish construction company in a matter related to loss carryforward regulatory.
A&S conducts a study related to business model options and taxes at source in target country for a Finnish mobile technology company.
A&S agrees to take care of a Finnish listed technology company's transfer pricing processes within the TP|BackOffice -concept.
A&S coordinates and administrates procedures related to establishing a Finnish branch for a Romanian energy company.
A&S assists a Finnish packing material manufacturer with tax audits in several countries.
A&S advises an industrial enterprise with design of a US business model.
A&S prepares a Polish transfer pricing documentation for a publicly listed company operating in process industry.
A&S assists a Finnish subsidiary of an international enterprise with tax audit defense.
A&S cooperates with a Finnish law firm in a tax audit defense case.
A&S reviews the tax filing of a Finnish listed group company.
A&S prepares a comparability study in respect of the management services to support a tax audit defense.
A&S assists a Finnish industrial enterprise in design of an international business model.
A&S assists a subsidiary of an international group in a tax audit defense.
A&S prepares transfer pricing documentation for Turkish subsidiary of a publicly listed automation technology company.
A&S performs a valuation related to business restructuring in healthcare industry.
A&S advises a Nordic service company with business restructuring.
A&S provides an opinion in a contract litigation case.
A&S prepares transfer pricing documentation for a power company.
A&S performs a comparability study to support the arm’s length nature of profit level achieved by a US subsidiary of a Finnish group.
A&S assists a Finnish public company with a foreign tax audit.
A&S assists a Finnish listed company in designing and implementing a centralized function to develop and maintain intangible rights.
A&S prepares transfer pricing documentation including two comparable searches for a global marketing service provider.
Mr. Linnanvirta has been nominated as a branch reporter for IFA 2012 Boston Congress.
A&S conducts feasibility study regarding centralized IP function and royalty scheme for a growing construction materials provider.
A&S performs a valuation of a Finnish media group.
A&S assists a high-tech consumer goods manufacturer in a tax audit defense.
A&S reviews transfer pricing report for a listed technology group.
A&S assists a Finnish multinational in providing responses to US IRS inquiries.
A&S performs a comparability study regarding arm’s length nature of a loan granted to a US subsidiary for tax audit defense purposes.
A&S prepares transfer pricing documentations in respect of royalties, cost sharing arrangement, financing and EEIG for a multinational packaging company.
A&S assists a Finnish publicly quoted company in transfer of trademarks.
A&S performs several comparability searches for subsidiaries of consumer goods company located in several different jurisdictions.
Mr. Leppänen acts as expert witness on transfer pricing in a civil court case at Helsinki District Court.
A&S assists Finnish software services company in centralizing IPRs.
A&S performs comparable search for a R&D service provider.
A&S cooperates with a Finnish law firm in a business model conversion case.
A&S drafts intra-group service agreement for a multinational environmental group.
A&S assists a project management system service provider in setting up centralized management.
A&S provides an international environmental firm with TP|SWOT concept.
A&S performs comparable searches and transfer pricing report updating for a Finnish MNE.
A&S assists a law firm in the preparation of the global documentation for a Finnish company operating in the finance industry.
A&S assists a Finnish law firm in the feasibility study related to a potential business restructuring.
A&S advises a subsidiary of a Swiss multinational in connection with the tax audit.
References
It is obvious that you understand your own business and industry better than any advisor, which is why it is usually important that you contribute to the project in a team with us. However, engaging an advisor who already has industry expertise means better pragmatic advice in a shorter time and thus, lower costs. Case examplesWe at A&S have experience in assisting clients operating in various lines of industries, including e.g. telecommunications, pharmaceuticals, consumer goods, manufacturing, finance and software development. Below are illustrated a few case examples of our previous engagements: Business model optimization - Centralizing IPRs – Valuation After being deemed as most potential conversion option, centralization of IPRs was taken further with centralized marketing function. The client was a Finnish stock listed group of companies located in over 10 countries. The group was operating in a decentralized business model. Even though the group was showing loss in certain countries and taxable profit in the other countries, the effective tax rate of the group as a whole remained high. In addition, the group had tax loss carry forwards in Finland that were about to expire.The group approached A&S and asked whether the losses in Finland could be used more efficiently and whether there is a way to control the profit level of the smaller group companies. As a solution, A&S suggested investigating opportunities available with a business model conversion. The conversion project was initiated and divided into three phases: feasibility study, detailed design and implementation. The feasibility study was performed with the assistance of TPA network and it consisted of a high level cost/benefit analysis of different alternatives for the conversion with the aim to provide most beneficial solution for the company. In the next stage A&S reviewed the activities of key group companies in order to identify the companies holding significant IPRs. In addition to the identification, A&S conducted the valuation of the IPRs and analysis of effects of the contemplated transfer. As a result of the study, it was decided to set up a centralized marketing function into the parent company and centralize existing marketing related IPRs into that company. In the final stage A&S assisted the company in drafting required legal documents for the transfer. In addition, A&S assisted the company in developing and documenting a royalty scheme for the marketing intangibles and the new group brand. With the new centralized IPR function and royalty scheme more taxable income from the profit-making entities could be channelled into Finland and the Finnish tax losses could therefore be utilized. As a result, the overall effective cash tax rate of the group could be reduced.
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It is of an utmost importance to understand the industry specific features in order to come to a proper analysis of the factors that should determine an appropriate measure in the respective circumstances.