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.
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Tax audit defense – Comparability study Performing a separate comparability study effectively subverted the tax authorities claim and demonstrated the reassessment presented being incorrect. The client was a leading designer and manufacturer of consumer goods, which were sold all over world by their own distributor network. The tax authorities disputed the comparability study performed by the client. The tax authorities argued that most of the companies were not acceptable comparables for various reasons and accepted only three of the presented companies as comparables. As a result, the tax authorities reassessed the profit level based on the median of these three companies, which was significantly higher than the median and the inter-quartile range of the original set of comparables.
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