Tax & Customs Experience

• TRANSACTIONS

  Advising Heidelberg Druckmaschinen, a leading solutions provider for the print media industry, on tax structuring and tax issues related to cross-border merger of its subsidiaries in Latvia, Estonia, Lithuania and Finland. Advice included choosing a jurisdiction for the parent company as well as support on taxation issues throughout and after the merger.

  Assisting Andrey Beskhmelnitskiy, a Russian entrepreneur, in acquisition of majority shares in Rīgas piena kombināts, the largest milk-processing enterprise in Latvia and one of the leading industrial enterprises in the Baltics. SORAINEN performed tax due diligence of the target and assisted the client throughout the acquisition process.

  Consulting AON, a leading provider of risk management services, insurance and reinsurance brokerage and human capital consulting, on tax aspects related to restructuring its subsidiaries in the Baltic States, advising on the choice of parent company for operations in the Baltics and assisting with tax issues related to implementation of the cross-border merger.

  Advising Euler Hermes Kreditversicherungs, the world's leading credit insurer, on various tax aspects related to one of the first and biggest cross-border business restructurings in the Baltic States. SORAINEN provided a tax analysis of the restructuring as well as step-by-step guidelines for its implementation.

  Advising Baltic Property Trust, an international real estate asset manager specialising in Central, Eastern and Northern Europe, in the course of its restructuring in Estonia, Latvia, Lithuania and Poland. Advice included separating assets from a tightly regulated fund management company.

  Assisting a multinational real estate and renewable energy group with taxation due diligence services in the process of acquisition of five Latvian companies holding wind generation licences and property leases.

• TAX STRUCTURING

  Advising Hitachi, a leading international technology company, on tax structuring, VAT, customs and other taxation issues related to the Visaginas nuclear power plant project in Lithuania. This is the largest investment project in the Baltic States since they regained independence and Hitachi will be involved as a strategic investor and EPC contractor.

  Assisting a group of private Lithuanian investors on tax structuring of high value green-field investment in a chain of retail stores in Belarus. SORAINEN advised the clients on holding company structure for operational and real estate companies in Belarus, exit strategy and structure for attracting potential additional investments. The SORAINEN team also devised a tax-efficient financing and intellectual property holding structure and advised on possibilities to reduce the effective tax rate in Belarus.

  Advising Western Union, a leader in global money movement and payment services, on VAT planning related to deductibility of input VAT as well as other tax issues related to structuring an investment in Lithuania. The beneficial tax structure devised by SORAINEN was one of the defining factors for the client to choose Lithuania as a place for their regional support centre.

  Advising Iberdrola Renovables, the world's largest wind power company, on tax aspects of restructuring and possibilities for tax savings in relation to operations in Estonia controlled by a Spanish company.

  Providing Seesam Insurance, a subsidiary of OP-Pohjola Group, a leading Finnish financial group, with thorough analysis of VAT issues on paying insurance indemnities.

  Assisting Scania Finans, a leading manufacturer of heavy trucks, buses and coaches and industrial and marine engines, on VAT and permanent establishment risk planning of cross-border supplies and financing acquisition of trucks that resulted from an intra-group transfer of business.

  Advising Airo Catering Services, an airline in-flight catering provider, in the course of introducing the EU VAT Package with respect to changes in the place of supply of services rules by creating innovative solutions.

  Seeking a binding preliminary ruling for Nordea, the largest financial services groups in the Nordic countries, regarding VAT treatment of realisation of a pledge. SORAINEN led negotiations with the tax authorities throughout the whole process to achieve the best result.

  Advising Phillips, one of the largest electronics companies in the world, on transfer pricing issues in relation to a tax audit of transactions with group manufacturing companies in other EU countries.

• TAX DISPUTES

  Successfully acting for Industriālais Termināls, a Latvian provider of industrial terminals, in a first ever VAT case decided by the Latvian Constitutional Court regarding the timing of introduction of the statute of limitation period for recovery of overpaid VAT.

  Successfully representing Stockmann, a leading Nordic department store, in overturning the decision of Latvian taxation authorities to impose taxes and penalties for failure to withhold withholding tax on consulting fees paid to a non-resident.

  Successfully representing Encorium Lithuania, a leading European clinical research organisation operating in more than 30 countries globally, in a highly complex tax dispute with the tax authorities regarding qualification of services in the light of Lithuanian Law on VAT, the EU VAT directive and ECJ case law and determining the place of supply of services.

  Advising and successfully representing Selver, a large food retail store chain, in a case against the Latvian taxation authorities on issues related to VAT recovery, cross-border movement of its own goods and intra community supply of goods when the client suspended its numerous retail locations in Latvia. The Latvian taxation authorities assessed approx EUR 200,000 in taxes and penalties, but following the explanations submitted based on ECJ case law the assessment was withdrawn without further litigation.