Ossi Haapaniemi

Partner, Helsinki

Ossi Haapaniemi is a Helsinki-based Partner specialized in tax law. He is a highly regarded advisor in tax disputes, ruling processes and high-end corporate tax matters, including complex cross-border transactions, and he has in-depth knowledge of corporate taxation, especially relating to financial instruments, corporate finance and capital market transactions and incentive schemes. Ossi has successfully represented clients in court proceedings concerning, for example, several landmark cases before the Supreme Administrative Court.

He is a frequent speaker at seminars, and he has authored numerous articles and books on taxation.

Ossi is ranked Band 1 in tax in Finland by Chambers Europe. He is also recognized as a leading expert by Chambers High Net Worth and other international ranking directories, such as The Legal 500 (Hall of Fame) and Who’s Who Legal. In addition, he has been awarded with the Best Lawyers – Lawyer of the Year award for Tax. According to Chambers Europe, Ossi is “highly regarded by market commentators for his experience in tax disputes”, and he also receives praise from clients for his “high-quality experience in tax issues” (Chambers Europe 2017). Further, clients describe him as “a prominent player” in the tax market and a “top-quality tax lawyer” (Chambers Europe, 2018).

Ossi Haapaniemi’s experience includes advising:

  • A client in filing a complaint against Finland to the EU Commission concerning group contributions in cross-border situations. The Commission decided to send a letter of formal notice to Finland asking it to amend its legislation to allow tax deductibility for contributions made to affiliated companies in other EU/EEA states to the extent that these cover definitive losses. Finland answered to the Commission that it will change the legislation.
  • A client in a state aid case (C-6/12) related to the selectivity in the Finnish special permission procedure concerning the utilization of tax losses following a significant change in the ownership of a Finnish company. In the case, the Finnish Supreme Administrative Court had requested preliminary ruling from the European Court of Justice and as a result, the client received the permission to utilize the tax losses;
  • A client successfully in a published landmark Supreme Administrative Court case where the Supreme Administrative Court annulled res judicata CFC decisions (including its own) because they were in conflict with a previous (C-196/04) ECJ decision;
  • Swedish foundations in dividend withholding tax reclaim cases where the Supreme Administrative Court decided, based on the EU principles, that non-residents should also receive interest for the amounts paid back. The Finnish legislation was later amended to correct the situation;
  • A client in a case recently published in the Supreme Administrative Court Yearbook concerning the question of whether the tax surcharge should be calculated on the basis of the gross amount or the net amount of the mistake;
  • A client successfully in a published landmark Supreme Administrative Court case concerning the allocation of income from employee options in cross-border situations. Due to the decision, the Finnish system was changed to better match the OECD principles;
  • A client in a case against the Finnish Tax Authorities in order to have the profit of MEUR 220 generated from a divestment of the client’s chemicals business declared tax exempt. The Finnish Supreme Administrative Court decided the case in favour of the client.

Roschier (2017-)
Hannes Snellman, Specialist Partner (2004), Partner (2005-2017)
Evli Corporate Finance/Evli Bank, Director and Partner (1997-2004)
Arthur Andersen Tax Consulting, Tax Consultant/Tax Manager (1993-1997)
Accounting and Consulting Firm Lehtola, Leppänen & Yli-Räisänen, auditor (bankruptcy estates) (1993)
Turku County Tax Office, tax auditor (1991-1993)

Member of the Finnish Bar Association
Member of the International Fiscal Association (IFA)
Member of the Finnish Tax Experts’ Association

CCBE Tax Committee, Member (2016-)
Member of the International Fiscal Association (IFA), Board member (2018-)
Tax Law Expert Group of the Finnish Bar Association, Member (2005-) Chairman (2006-2018)
Finnish Tax Experts’ Association (SVA) , Board member (2005-), Chairman (2010-2012)
Tax working group of the Finnish Federation of Industry, Member (2005-)
Tax working group of the Finnish Association of Securities Dealers, Member (1998-2004)

“EU-oikeuden vastaisten päätösten korjaaminen” (“Measures to correct decisions against the EU Law”), in Verotus 2/2018

“Oikeusvarmuus ja ennustettavuus sekä lailla säätämisen vaatimus – Esimerkkinä oman ja vieraan pääoman määrittely siirtohinnoittelusäännösten perusteella” (“Legal certainty and predictability as well as the requirement of law – Highlighted by the example of defining equity and debt based on transfer pricing rules”), in Vero ja finanssi Juhlakirja Matti Myrsky 60 vuotta, 2013

“Osakeperusteisten kannustinjärjestelmien verokohtelun uudet ongelmat” (“New problems related to the tax treatment of share-based incentive schemes”), Minne menet vero-oikeus? Juhlajulkaisu Raimo Immoselle, 2013

“Foreign exchange issues in international taxation”, Finnish national report for the 2009 IFA Congress

“Osakevaihto ja rahavastikkeen maksimimäärä” (“Exchange of shares and maximum cash consideration”), In memoriam Kari S. Tikka 1944-2006, 2007

“Osakeperusteisten kannustinjärjestelmien verotus” (“Tax treatment of stock-based incentive schemes”), dissertation, 2006

“Tax treatment of hybrid financial instruments in cross-border transactions”, Finnish national report for the 2000 IFA Congress

“Rahoitusinstrumentit” (“Financial Instruments”) with Marja Tikka, 1999

“Verosuunnittelun käsikirja I” (“Tax Planning Handbook I”) with Jarmo Ikkala, Raimo Pallonen and Outi Raitasuo, 1997

University of Helsinki, LL.D. (2007)
University of Turku, LL.M. (1994)
Turku School of Economics, M.Sc. (Econ.) (1992)

English, Finnish

A prominent player in the tax market and a top-quality tax lawyer. Chambers Europe