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May-June 2007
Estonia, Latvia, Lithuania, Finland, Sweden |
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RoschierRaidla News
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Inside this Issue:
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Estonia |
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Latvia |
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Lithuania |
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Estonia
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Estonian National Broadcasting Act Adopted |
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On 18 January 2007 the Estonian Parliament (Riigikogu)
adopted the Estonian National Broadcasting Act. Under the new act
the public television and radio organizations of Eesti
Televisioon and Eesti Raadio, which to date had been
operating as separate legal entities are merged and become a single
new public legal entity, called the national broadcast entity (Eesti
Rahvusringhääling). The new act prescribes the legal status,
objective and tasks of the national broadcast entity, as well as the
organization of its funding, management and activities. Based on the
law, the national broadcast entity is obligated to help satisfy
related goals set forth in the Estonian Constitution. As a rule, the
national broadcast agency shall not broadcast advertising or tele-shopping
and shall not accept support in the form of sponsorship. The law
entered into force on 1 June 2007.
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Changes in Taxation Act |
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On 15 February 2007 the Riigikogu passed the Taxation Act
Amendment Act. Most importantly, the amendments allow undertakings
to seek binding preliminary rulings concerning the tax treatment of
anticipated transactions from the Tax and Customs Board. This comes
into effect at the beginning of 2008. The aim of the new approach is
to offer taxpayers more legal certainty and help them reduce tax
risks related to new transactions and combinations of transactions.
Undertakings are free to choose whether to follow the ruling or not,
but if they do, the tax authority must observe the ruling. The tax
authorities also must set forth on their website summaries of such
preliminary rulings that describe transactions of general importance
or which have been the object of repeated requests for preliminary
rulings. At the same time the tax authorities must maintain
confidentiality and may not publish data that could lead to the
disclosure of persons involved in any individual transactions.
Undertakings may not seek preliminary rulings in matters pertaining
to determining the value of transactions between associated persons.
Under the law the tax authority may refuse to issue a preliminary
ruling in the event that the application of the legal provisions is
clear, the transaction is hypothetical or the purpose of the
transaction is tax evasion. The fee for review of an application for
a preliminary ruling is 1 200 EEK (c.a. 77 EUR). In addition, the
law now allows the Tax and Customs Board to delete at its own
initiative from the register sole proprietors who are not actually
engaged in business activities. The tax authorities are also granted
the right to question any person who is present on the premises on
the basis of an observation, and if reasonable doubt exists, to
submit a bankruptcy petition before the performance of enforcement
actions by the tax authorities or a bailiff. Most of the amendments
enter into force on 1 July 2007, some provisions are in force from
16 March 2007 and some shall enter into force on 1 January 2008.
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Provisions of Electricity Market Act Amended |
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On 21 February 2007 the Riigikogu passed the Electricity
Market Act Amendment Act. The objective of the amendment is to
transpose European Union directives 2001/77/EC and 2004/8/EC and to
promote generation of electricity produced from renewable energy
sources as well as cogeneration, while maintaining the security of
supply of the Estonian electricity system. A further aim is to
harmonize the provisions of directive 2003/54/EC concerning common
rules for the internal market in electricity. Among other things,
the amendments lay out a development plan for the electricity
sector, clarify the rights of eligible consumers, as well as issues
pertaining to activity licenses of network service providers. Under
the new provisions it is possible to launch a tendering procedure in
case the system of granting activity licenses fails to bring a
sufficient number of producers to the electricity market to meet
consumption demand. Producers using wind as their source of energy
shall have to ensure the electricity balance on an equal footing
with all other market participants. Legislation regulating
guarantees of origin was introduced as well. Pursuant to the law,
transmission network operators must issue a guarantee of origin to
the producer upon the request of the latter, certifying the
generation of electricity from a renewable source of energy or by
using high-efficiency cogeneration. The law also introduces new
principles for supporting entry into the market of producers using
renewable sources of energy and cogeneration. Under the new scheme
producers may continue to use the obligation to purchase or sell
electricity on their own and receive a subsidy for electricity
transferred to the network and sold. The amendments also introduce
the possibility for commercial consumers to reach agreement with
sellers concerning more suitable selling conditions, which differ
from standard terms and conditions. Under the new rules network
operators and sellers must begin disclosing certain prices of
electricity sold as well as various other data on their websites.
Most of the amendments entered into force on 1 May 2007, with some
coming into effect from 1 January 2009 and 1 January 2010.
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Provisions Governing Utility Works and
Networks Specified |
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On 21 February 2007 the Riigikogu adopted provisions
concerning utility works and networks. A provision was added to the
General Part of the Civil Code Act to the effect that utility works
or utility networks are deemed to be separate from immovables. The
rights and obligations pertaining to accommodating utility works and
networks are introduced both for the owners of immovables and for
the owners of utility works and networks. Among the new developments
is a provision for payment for accommodating utility works. The
Building Act specifies provisions concerning the issuing of building
permits and authorizations for use. Utility networks must be entered
in the state construction register by 1 April 2009 at the latest.
The general principles of planning utility works and networks were
specified in the Planning Act. The amendments entered into force on
26 March 2007.
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Value Added Tax Act Amended |
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On 8 February 2007 the Riigikogu adopted the Value Added Tax
Act Amendment Act. The amendments introduce legislation, which
allows undertakings meeting certain conditions to state value added
tax due on imported goods in their value added tax return. Prior to
this change value added tax on imports had to be paid at the moment
of releasing the goods for free circulation. Certain chemical pest
control agents will now be taxed at the regular 18% rate instead of
the current 5%. A value added tax exemption was introduced to
services provided as part of their professional activities by dental
technicians. Further specifications were added with respect to
requirements for invoices. The provisions regulating the placing of
supply of electronically supplied services as well as the special
regime of taxation of such services are now valid indefinitely. The
amendments entered into force on 1 March 2007, except those, which
await entry into force on 1 January 2008.
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New Personal Data Protection Act Adopted |
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On 18 February 2007 the Riigikogu passed the Personal Data
Protection Act. The purpose of the Act is to protect the fundamental
rights and freedoms of natural persons with regard to processing of
personal data, in particular the inviolability of private life. The
law specifies sensitive personal data as a type of personal data
requiring special protection. The conditions for registering the
processing of sensitive personal data have been simplified. As a
rule, processing of personal data requires the consent of the data
subject, which may be partial or conditional. A separate provision
prescribes the right of the data subject to prohibit all processing
of data concerning the data subject. As a rule, processing of
personal data is permitted without the consent of the data subject
if processing is conducted in coded format. The rights of data
subjects include the right to receive information and personal data
pertaining to the data subject, the right to demand termination of
processing or amendment of personal data. The act enters into force
on 1 January 2008.
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| For further information please contact
Raino Paron,
Partner at Raidla &
Partners in Tallinn. |
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Latvia
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Legislative Measures Introduced to Combat
Inflation in Latvia |
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On 17 May 2007 the Saeima (the
Latvian Parliament) amended a number of laws
in order to implement certain
legislative measures under the
government’s anti-inflation program.
Among others, amendments were made
to the Law on
Individual’s Income Tax, Law on
Enterprise Income Tax, Consumer
Protection Law and Law on Credit
Institutions. The amendments entered
into force on 12 June 2007. While the
practical intricacies of the
application of the new provisions
still remain to be tested, a number
of uncertainties and interpretation
difficulties already have arisen.
Amendments to the Law on Individual’s
Income Tax
Amendments to the Law on Individual’s
Income Tax primarily concern taxation of
income from the sale or transfer of real
estate. Thus, the law “On Amendments to the
Law on Individual’s Income Tax” has
withdrawn the existing tax exemption
under which capital gains from the sale
of an individual’s real estate were not
taxed if the real estate was owned by
the individual for at least 12 months
before its sale, and has introduced a
new exemption under which the capital
gains would only be tax exempt if the
real estate was owned by the individual
as its private property for at least 60
months (as of the date of registration
of the individual’s title to the real
estate in the Land Register) and the
individual had its declared place of
residence (domicile) in that real estate
for at least 12 months prior to the date
of transfer. The taxable amount of
capital gains from the sale or transfer
of real estate will be determined by the
difference between the real estate
transfer price and the real estate
acquisition price and certain
acquisition costs (notary fees, state
duties, court fees and duties payable in
inheritance cases, and other similar
expenses).
In the period until 1 July 2010 the new
capital gains tax will not be applicable
to sale of real estate which was owned
by the taxpayer on or before the date
the new tax regime entered in force,
i.e. on or before 12 June 2007, provided
that the tax payer’s title to the land
has been duly registered in the land
register prior to 12 June 2007 or, if
not, that the title will be duly
registered by 31 December 2008 or any of
the other special conditions set out in
the transitional provisions of the Law
on Individual’s Income Tax are
applicable.
Taxation of capital gains will also
apply to capital gains from sale or
transfer of shares in certain real
estate companies. Latvian tax residents
will be required to pay income tax on
the capital gains obtained in sale or
transfer of shares or other form of
participation in such Latvian or foreign
companies or other parties the asset
value of which during the year when the
shares (or other form of participation)
are sold, or during the immediately
preceding year, by more than half (50%)
consisted of, directly or through
participation in one or several Latvian
or foreign companies, the value of the
real estate in Latvia. The determination
of whether or not the income obtained
from the sale of shares is subject to
capital gains tax has to be made based
on the company’s balance sheet as at the
beginning of the respective year. While
there will be no difficulty to make the
determination when the shares are sold
by a person which has incorporated and
operated or controlled the business shares in
which he/she is selling, it is not clear
how the new capital gains tax will be
applied, for example, to sale of shares
in listed companies by a minority
shareholder, or in other cases when the
selling shareholder does not have
sufficient data available to make the
relevant calculations, especially in
respect of the value of indirectly held
real estate.
The same rules will also apply to
taxation of capital gains of
non-residents.
New tax exemption has been introduced
in respect of income obtained in the sale of
investment fund certificates. In
addition, costs of acquisition of
investment fund certificates of the
funds established in Latvia or other EU
or EEA member state will be tax
deductible if the respective investment
certificates have been held by the tax
payer for at least 60 months, provided
that these costs do not exceed 20% of
the tax payer’s annual taxable income.
Amendments to the Law on Enterprise
Income Tax
The Law on Enterprise Income Tax has
been amended to exclude from the tax
deductible business expenses the costs
of acquisition of motor vehicles
which qualified as "representative cars", as
well as to introduce a withholding tax
on certain capital gains obtained from
the sale of shares.
For the purposes of the Law on
Enterprise Income Tax a car will be
deemed to be a representative car if it
has not more than 8 seats, and the value
of which (excluding VAT) is more than
25 424
LVL (approximately 36 175 EUR). The
rule will not apply to certain types of
special transport, as well as to cars
acquired by authorized dealers for representation purposes. According to
the amendments the costs of acquisition
of representative cars, including
acquisition in financial leasing, as
well as their maintenance and service
costs will not qualify as a tax
deductible business cost, except if the
tax payer is engaged in the business of
leasing vehicles and more than 90% of
its annual revenue is obtained from the
business of leasing vehicles.
The law has been supplemented with a new
provision on withholding tax on capital
gains obtained by non-resident legal
entities from the sale of shares or
other form of participation in Latvian
or foreign companies or other parties
the asset value of which during the year
when the shares (or other form of
participation) are sold, or during the
immediately preceding year, by more than
half (50%) consisted of, directly or
through participation in one or several
Latvian or foreign companies, the value
of the real estate in Latvia. The
applicable withholding tax will be 2% of
the income obtained. The withholding tax
will not apply if the respective company
is a company whose shares are traded in
a regulated market in Latvia or in
another member state of the EU or EEA, or if
the income is obtained in sale of
investment certificates of investment
funds established in Latvia or in
another EU or EEA Member State.
Amendments to the Law on Credit
Institutions
The Law on Credit Institutions has been
amended in order to create a legal basis
for the establishment of the Borrowers
and Guarantors register. The register
will be maintained by the Bank of Latvia
based on the data collected by the Bank
of Latvia from all banks and their
subsidiaries engaged in financial
services involving a credit risk. All
banks and their subsidiaries engaged in
financial services involving a credit
risk will be subject to the Bank of Latvia’s
requirements concerning delivery of
information for the purposes of the
Borrowers and Guarantors register. The
above requirements, however, will not
apply to non-banking entities like
leasing companies and consumer credit
institutions which are not owned or
controlled by a bank.
The Amendments to the Law on Credit
Institutions will also introduce new
penalties payable by credit institutions
in respect of breach of certain
credit restrictions. Thus, any credit
institution which has granted a loan to
a consumer
exceeding
an amount equivalent to 100
minimum salaries (at present
120
LVL
per month) or more without obtaining
a State Revenue Service’s certificate on
their income, may be subject to a
fine of
1 000
LVL (~
1 423
EUR). For a repeated offence the credit
institution may be subject to fine of
3 000
LVL (~
4 269
EUR). The same
penalties will apply if the credit
institution has granted a loan in an
amount equivalent to 100 minimum salaries or more
secured by a mortgage in the amount of
90% of the respective collateral value,
or if a loan in an amount equivalent to 100
minimum salaries or more is granted to
the borrower without the Borrower’s own
participation.
Amendments to the Law on Consumer
Protection
The Law on Consumer Protection has been
amended to introduce more strict
requirements concerning issuance of
consumer credit in an amount equivalent
to 100
minimum salaries or more (~
17 075
EUR).
The new rules are almost identical to
the new penalty provisions in the Law on
Credit Institutions described above,
i.e., no consumer loan may be granted in
an amount equivalent to 100 minimum
salaries or more unless the consumer
provides their own financing in the amount of
at least 10%, and no mortgage loans can
be issued for more than 90% of the
mortgaged real estate value. The new
rules will apply both to regulated
financial institutions, as well as
non-regulated consumer financing
providers like leasing companies and
consumer credit institutions. The rules
are not applicable to consumer credit
to residents of other countries, except
where they are granted for the purposes
of acquisition of real estate or another
asset subject to registration in Latvia.
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| For further information please contact
Dace Silava-Tomsone
(CV),
Partner at Lejins, Torgans
& Partners in Riga. |
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Lithuania
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Amendments and Supplements to the
Lithuanian Patent Law |
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On 10 May 2007 the Lithuanian Parliament
(Seimas) amended and supplemented
the Lithuanian Patent Law. The
modifications made have implemented
Regulation (EC) No 816/2006 of the
European Parliament and of the Council
of 17 May 2006 on compulsory licensing
of patents relating to the manufacture
of pharmaceutical products for export to
countries with significant public health
problems. This Regulation establishes a
procedure for the issuance of compulsory
licenses in relation to patents and
supplementary protection certificates
concerning the manufacture and sale of
pharmaceutical products, when such
products are intended for export to
eligible importing countries in need of
such products in order to address public
health problems. The Regulation is
intended to be a part of wider European
and international action to address
public health problems faced by the
least developed countries and other
developing countries, and in particular
to improve access to affordable
medicines which are safe and effective
and whose quality is guaranteed.
Noteworthy is that any company in the EU
may apply for a license to manufacture
pharmaceutical products – without the
authorization of the patent holder.
Accordingly, the Government of the
Republic of Lithuania has undertaken to
designate a competent authority which
would be entrusted with the granting of
compulsory licenses under the national
patent law. Under the Regulation, the
issuance of a license must be
communicated to the European Commission.
The amount of products manufactured
under license may not exceed that which
is necessary to meet the needs of the
importing countries. In addition,
products made under license are required
to be clearly identified through
specific labeling or marking
requirements (shape, color etc.).
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Lithuanian Law on Construction Amended |
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On 3 May 2007 the Lithuanian
Parliament (Seimas)
adopted amendments to the
Law on Construction. The
amended law establishes
stricter requirements in
respect of the preparation
of building design
conditions, issuance of
compulsory building design
documents and implementation
of building design
inspection and control.
Stricter conditions have
also been established in
respect of the building
usage as well as issuance of
building construction
permits. In order to reduce
bureaucratic procedures, the
requirement of compulsory
registration of construction
rules with the Ministry of
Environment was withdrawn.
Among other amendments, the
law also implemented the
principle of mutual
acknowledgement with regard
to construction products
that were legally produced
in Turkey or legally
imported from a third
country to Turkey.
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New Wording of the Lithuanian Law on
Natural Gas |
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On 19 April 2007 a new
wording of the Law on
Natural Gas came into force.
The law aims at harmonizing
national legal acts
regulating activities in the
natural gas sector with the
Directive 2003/55/EC
concerning common rules for
the internal market in
natural gas and repealing
Directive 98/30/EC as well
as with Directive 2004/67/EC
concerning measures to
safeguard security of the
natural gas supply. The new
wording seeks to establish
general principles in
respect of the activities
carried out in the natural
gas sector, its organization
and functioning,
inter-relations among gas
companies and relations with
the consumers while
supplying, distributing,
transferring, liquefying and
storing natural gas. A new
gas market liberalization
schedule has also been
introduced whereby
non-domestic consumers
gained the right to choose a
gas supply company freely as
of 1 July 2004 and all other
consumers are going to be
granted such right as of 1
July 2007. Other significant
changes include a new
obligation of the integrated
gas companies to separate
transfer, distribution and
other activities from the
gas supply activities in
their companies, and new
requirements aimed to secure
gas supply activities.
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| For
further information please contact
Irmantas Norkus, (CV),
Managing Partner at
Norcous & Partners in Vilnius. |
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Finland
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Implementation of the
Transparency Directive and
Disclosure of Shareholdings |
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The EU Transparency
Directive (2004/109/EC) was
implemented into Finnish law
on 15 February 2007. As a
result of the
implementation, inter
alia, certain provisions
of the Finnish Securities
Market Act (495/1989) were
amended as well as two
Finnish Ministry of Finance
regulations updated. The new
provisions regulate listed
companies’ regular reporting
requirements, the
publication and availability
of company-specific
information as well as the
shareholder’s duty of
disclosure. The following
discussion focuses on the
disclosure of shareholdings
in listed companies.
Most of the provisions
relating to the
shareholder’s duty of
disclosure, including the
current thresholds (5, 10,
15, 20, 25, 30, 50 and 66.7%
of the share capital or the
voting rights) triggering
the disclosure obligation,
remain unchanged in
connection with the
implementation of the
Directive. However, a new
Ministry of Finance Decree
on Disclosure of Holdings
(154/2007) introduces
certain amendments, such as
new exemptions from flagging
obligations.
In accordance with the new
provisions, a parent company
of a mutual fund company or
a securities dealer
authorized in an EEA member
state is not obliged to
aggregate its holdings with
shares owned by an
investment fund or
collective investment
undertaking, or with shares
held as a result of asset
management agreements if the
voting rights pertaining to
the shares are exercised
independently of the parent
company. Application of the
exemption requires a
notification for this
purpose to be filed with the
Finnish Financial
Supervision Authority (FFSA).
A similar exemption applies
to parent companies
authorized outside the EEA
as well but this exemption
presupposes a separate
application to be filed with
the FFSA which may grant the
permission at its
discretion, provided,
inter alia, that it
considers the home state
legislation of the non-EEA
mutual fund company or
securities dealer
sufficient.
In addition, shares held by
a market maker authorized in
an EEA member state are to
be disregarded for the
purpose of determining the
disclosure obligation if
such holding would lead to
the relevant threshold of 5%
being reached or exceeded or
if the holding would fall
below 5%, subject to the
market maker not influencing
the management of the
issuer. Further, shares
acquired for the sole
purpose of clearing and
settlement for a period of
not more than four trading
days are exempted from the
disclosure obligation.
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| For further information please contact
Dimitrios Himonas
(CV),
Partner at Roschier in Helsinki. |
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Sweden
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New Disclosure
Rules as of 1 July
2007 |
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A new law
regarding the
implementation
of the EC
Transparency
Directive
(2004/109/EC)
was passed on 30
May 2007. The
new law
implements new
disclosure rules
in the Swedish
market as of 1
July of this
year.
Disclosure
obligations
under the new
disclosure rules
will be
triggered at
percentages of
5, 10, 15, 20,
25, 30, 50, 66.7
and 90 of the
shares owned as
well as at the
voting
thresholds. The
matrix below
provides a
comparison with
the current
regime:
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Old law
(votes
only) |
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10 |
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20 |
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33.3 |
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50 |
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66.7 |
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Old self
regulation
(votes
and
shares) |
5 |
10 |
15 |
20 |
25 |
30 |
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35 |
40 |
45 |
50 |
55 |
60 |
65 |
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70 |
75 |
80 |
85 |
90 |
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New law
(votes
and
shares) |
5 |
10 |
15 |
20 |
25 |
30 |
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50 |
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66.7 |
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90 |
Interestingly
enough, the new
law implementing
the Transparency
Directive will
give rise to
less
transparency
than the current
national regime.
Except for the
fact that there
will be fewer
thresh-olds,
certain actions
such as the
execution of
option
agreements
(which are not
financial
instruments)
will not trigger
disclosure
requirements.
The transitional
provision of the
proposed law
will impose
initial
disclosure
requirements on
shareholders
that have passed
the thresholds
set out in the
new rules
without having
disclosed their
acquisitions.
However, if the
same information
has been
provided to the
market under the
old regime, no
one-time
disclosure will
have to be made
at the time when
the new law
comes into
force. Since
most
shareholders
have already
made an
announcement
when they passed
the thresholds
of the new law
under the old
rules, very few
shareholders are
expected to make
any additional
disclosure.
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New Equity
Financing Product |
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A new equity
financing
product, Standby
Equity
Distribution
Agreement (SEDA),
has recently
been accepted in
principle by the
Swedish
Securities
Council and
introduced to
the Swedish
market.
In brief:
-
SEDAs
provide
companies in
growth and
early phases
with the
opportunity
to quickly
and
relatively
cost
efficiently
get access
to
additional
equity
funding.
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SEDAs are
acceptable
from a
Swedish
stock market
perspective.
-
SEDAs as
currently
structured
are not
legally
enforceable.
Such
agreements
should hence
only be
entered into
with
reliable
investors
who can not
afford the
reputational
loss of
walking away
from their
obligations.
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Incentives
to honor the
unenforceable
contractual
obligations
can be
created by
way of
liquidated
damages
payable to a
third party.
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A discount
for the
share
subscriber
of four
percent to
the market
price is per
se on market
terms.
The Swedish
Securities
Council has
approved the use
of standby
equity
distribution
agreements in
the statement
(2007:09). In
the proposed
structure,
Cornell Capital
Partners enter
into an
agreement with
small and mid
cap listed
companies
pursuant to
which it is
committed to
subscribe for
shares on demand
from the
companies. This
provides the
companies with
the opportunity
to quickly and
relatively cost
efficiently get
access to
additional
funding. This is
especially
attractive for
companies in
growth or early
phases without a
positive cash
flow. The
Securities
Council found
that the
arrangement was
acceptable from
the perspective
of good stock
market practice.
The Securities
Council has
previously
stated that the
market price for
listed shares
shall serve as a
benchmark for
setting the
subscription
price in a
directed share
issue. A smaller
discount to the
market price is
acceptable if it
is on market
terms. Larger
discounts must
be motivated by
strong and
exceptional
circumstances. A
discount of four
percent was per
se considered to
be on market
terms by the
Council in
statement
2007:09.
The decision is
interesting
because it
further
clarifies the
view of the
Council on
directed share
issues. It is
the common view
that a company
that needs
additional
equity should
offer its
shareholders
subscription of
the new shares
on a pro rata
basis and only
take dilutive
measures such as
directed share
issues as a last
resort. Also, if
directed share
issues are made
to a
shareholder, the
other
shareholders
should, as a
general rule, be
compensated to
avoid any
dilution and
unequal
treatment, even
if the share
issue is made on
market terms.
Sweden clearly
takes a much
stricter and
less
market-friendly
approach than
many other
countries in
this respect.
Standby Equity
Distribution
Agreements are
acceptable if it
is not
practicable to
request
additional
equity from the
shareholders.
Standby equity
distribution
agreements
between the
company and the
investor only
will not be
legally
enforceable in
Sweden (as is
equally the case
with
underwriting
agreements
entered into
between the
issuer and the
underwriter
only). The
reason for the
unenforceability
is that the
company may not
deviate from the
procedural rules
of the Companies
Act requiring
certain
formalities when
issuing new
shares. We find
it less likely
that large
financial
institutions
will not live up
to their
obligations
regardless of
the formal
validity of the
agreement.
However,
agreements
between the
issuer and
underwriter
only, should
certainly not be
entered into
with investors
of a less than
solid
reputation.
Alternatively,
incentives to
honor the
contractual
obligations can
be created by
way of
liquidated
damages payable
to a third
party.
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| For further information please contact
Axel Calissendorff
(CV),
Partner at Roschier
in Stockholm. |
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| This Newsletter is a
periodic publication of RoschierRaidla and
should not be construed as legal advice or legal opinion on any specific
facts or circumstances. We have used reasonable efforts in collecting,
preparing and providing the information in this newsletter, but we do
not warrant or guarantee the accuracy, completeness, adequacy or
currency of the information contained herein. The contents are for
general informational purposes only, and you are urged to consult a
lawyer concerning your situation and any specific legal questions you
might have. |
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