We are currently engaged in legal proceedings against an Estonian company owned by Finnish and Estonian citizens.
We have engaged into an extensive analysis of the available financial and corporate information regarding these individuals and have discovered the existence of a large scale organization providing tax evasion and tax fraud facilities for Finnish citizens and Finnish companies.
This organization is owned by Finnish and Estonians, Estonian managed and its “customers” are Finnish taxpayers, both corporate and individuals.
According to our information (which is public and available from the Estonian Register of Commerce), the Estonian company Office Services Group OU (reg. number 11374672) is, directly or through its subsidiaries Administration Services OU (12126864), Offices Services OU (11078873), Financial Services OU (11877485) and Legal Services OU (12126864) providing incorporation services, “accounting” services and secretarial services to Finnish citizens and companies. These companies are managed by the Estonian Citizen Mirjam-Mari Marastu.
The companies thus created have the common characteristics :
– They are headquartered at the same address (Valge 13, Tallinn, headquarters of Office Services OU, Administration Services OU, Financial Services OU,…)
– They are providing for sole contact details phone numbers and emails owned by Offices Services Group OU and its subsidiaries, showing the non-existence of an independent and real business.
– They are failing to publish their financial results, providing total opacity.
– They have no employees beyond the shareholders (Finnish citizens) and managers
The use of these companies is allowing the Finnish citizens to:
(i) Hide their ownership of assets in Estonia from the Finnish tax authorities
(ii) Receive revenue, in Estonian bank accounts, from these companies while not declaring it to the Finnish tax office
(iii) Lower their companies taxable income in Finland by either (a) directly issuing invoices or receiving funds on the Estonian companies for products / services which are in fact delivered by the Finnish companies, and/ or (b) invoicing the Finnish companies for fictious provision of goods or services and / or (c) receiving funds from the Finnish companies which are then “reinvested” into fictious assets, and /or (d) lowering the reported value of the Estonian owned assets in the accounting of the Finnish companies.
We are sure that a cautious study by the Finnish Tax Administration of the declared assets and revenues of these Finnish citizens and Companies, as well as of the purchases made by the Finnish Companies from Estonian companies will allow the Finnish Tax Administration to detect the discrepancies in declarations and the fraudulous / ungrounded transactions, and therefore will allow Finland to recover the substantial amounts which have been evaded through these channels.
- A. Individuals using bogus Estonian companies in order to hide their ownership of real estate in Estonia and the revenues from such real estate from Finnish Tax Authorities :
Juhana Lauri Virkkunen, (DOB 16.03.1972) co-manager and co-shareholder of 3a-Investments OU (Valge 13, reg number 12125735), share capital 2 500 €.
Ari Tapio Lehtoranta (DOB 22.04.1963), sole shareholder and manager of Hisra Investment OU (Valge 13, reg. number 11299054), share capital 50 000 EEK, ie around 3 000 €
Jukka Matti Harju (DOB 12.07.1950), sole shareholder and manager of Navitrek OU (Valge 13, reg number 11182659), share capital 50 000 EEK, ie around 3 000 €
Kirsti Hannele Mäenpää (DOB 20.07.1951), Mikko Tapani Mäenpää (DOB 18.03.1980), Osmo Tapani Mäenpää (DOB 30.10.1948), shareholders and managers of Skarpenfelt OU (Valge 13, reg number 12079308), share capital 2 500 €
The sole activity of these companies is to own shares of the Estonian company BOLTON REAL ESTATE, (Valge 13, reg number 11052218), managed by the Estonian citizen Mirjam-Mari Marastu (also director of Office Services Group OU, Office Services OU, Financial Services OU,…..), and which has a registered share capital of 8 161 620 EUR, and is officially owning the following real estate assets :
Harjumaa, Tallinna linn, Põhja-Tallinna linnaosa, Paljassaare tee 28E (Estonian cadaster 78408:809:0001, immovable number 12418901)
Harjumaa, Tallinna linn, Põhja-Tallinna linnaosa, Paljassaare tee 30c
(Estoninan cadaster 78408:809:0620, immovable number 16637601)
3a-Invetment OU shareholding in Bolton Real Estate is 111 726 €
Hisra Investment OU shareholding in Bolton Real Estate is 237 012 €
Navitrek OU shareholding in Bolton Real Estate is 204 799 €
Skarpenfelt OU shareholding in Bolton Real Estate is 191 710 €
As a result, instead of reporting to the Finnish tax authorities the ownership of assets in a combined value of around 750 000 € (Bolton Real Estate registered shares), these individuals report a combined value of around 10 000 € (aggregated capital of the bogus companies headquartered in Valge 13). Also, the revenues declared by these individuals (if any) is the revenue generated by their bogus companies, and not the dividends paid by Bolton Real Estate OU to their bogus companies.
Note #1 :
Bolton Real Estate has also other Finnish citizens as direct shareholders, and it is not sure that these individuals are properly reporting their assets to the Finnish Tax Administration.
These individuals are :
Jorma Junahi Kasslin (DOB 07.07.1953) holder of shares for a total amount of 349 092 €
Pauli Juhani Pekonen (DOB 03.06.1955), holder of shares for a total amount of 88 477 €
Note #2 :
The Finnish Citizen Bror Jan-Henrik Ralfson Schauman (DOB 12.09.1945), was, from June 2006 to September 2011, direct shareholder of Bolton Real Estate in an amount of 1 317 600 EEK (around 84 000 €). Since this date, this ownership has been transferred to Barken Kapital OU, Estonian company register code 12044385, sole owner OY Barken AB, managed by ), managed by Bror Jan-Henrik Ralfson Schauman, Joen Börje Gustav Schauman (DOB 11.07.1979) and Barbro Gunilla Planting-Schauman (DOB 01.01.1946). The registered capital of this company is 2 500 €.
It is unclear whether or not Bror Jan-Henrik Ralfson Schauman has declared to the Finnish Tax Authorities its initial ownerhip into Bolton Real Estate or the financial conditions in which such shares have been transferred to BARKEN KAPITAL OU, just as it is unclear whether or not OY BARKEN AB has declared its ownership within BARKEN CAPITAL OU to the Finnish Tax Authorities.
Note #3 :
The Finnish Citizen Eero Olavi Makkonen (DOB 02.04.1946) was, from June 2006 to May 2007, a direct shareholder of Bolton Real Estate, in an amount of 2 474 600 EEK (around 158 000 €). Since this date, it is the company EMCON OU (Valge 13, reg number 11388473), which he co-manages with Finnish Citizen Juha Ossi Kajavuori (DOB 26.01.1954) and whose sole shareholder is the Finnish company EMCON OY, who is the owner of these shares.
As of today, the value of the registered shares owned by EMCON OU in Bolton Real Estate is 388 934 €. EMCON OU has a share capital of 50 000 EEK (around 3 000 €).
It is unclear whether or not Eero Olavi Makkonen has declared to the Finnish Tax Authorities its initial ownerhip into Bolton Real Estate or the financial conditions in which such shares have been transferred to EMCON OU, just as it is unclear whether or not EMCON OY has declared its ownership within EMCON OU to the Finnish Tax Authorities.
Note #4 :
The Finnish Citizen Osmo Tapani Mäenpää (DOB 30.10.1948) was, from June 2006 to May 2011, a direct shareholder of Bolton Real Estate in an amount of 1 712 900 EEK (around 109 000 €). Since this date, it is the company Skarpenfelt OU (Valge 13, reg number 12079308), share capital 2 500 €, which he co-owns and co-manages with Finnish Citizens Kirsti Hannele Mäenpää and Mikko Tapani Mäenpää which is the owner of the said registered shares (amounting today to a registered value of 191 710 €).
It is unclear whether or not Osmo Tapani Mäenpää has declared to the Finnish Tax Authorities its initial ownerhip into Bolton Real Estate or the financial conditions in which such shares have been transferred to Skarpenfelt OU, just as it is unclear whether or not Osmo Tapani Mäenpää has declared its ownership within Skarpenfelt OU to the Finnish Tax Authorities.
Note #5 :
The Finnish Citizen Lars Erik Ollberg (DOB 29.11.1956) was, from June 2006 to June 2009, a direct shareholder of Bolton Real Estate, in an amount of 823 600 EEK (around 52 000 €). Since this date, it is the Finnish company Promitos OY (reg. number 2241771-2) who is the own of these shares, which are amounting today to a registered value of 94 796 €.
It is unclear whether or not either Lars Erik Ollberg or Promitos OY have declared to the Finnish Tax Authorities their ownership of these shares or the financial conditions of transfer of these shares to Promitos OY, and whether or not Promitos OY has reported their current registered value to the Finnish Tax Authorities.
Note #6 :
The Finnish company OY Attica (registration number 0709130-4) was, from June 2006 to December 2010 a direct shareholder of Bolton Real Estate, in an amount of 1 152 900 EEK (around 73 000 €). Since this date, it is the Estonian company Attica Eesti OU (reg. number 12006628, share capital of 2 500 €) which is the owner of these registered shares, whose registered value is as of today 196 975 €.
Attica Esti OU is owned and managed by Maria Elisabeth Planting, (DOB 22.02.1954) Sam Arvid Mikael Planting (DOB 13.09.1952) and Bettina Margaretha Sandboge, (DOB 27.12.1982) who are also shareholders and managers of Attica OY in Finland.
It is unclear whether or not Attica OY has declared to the Finnish Tax Authorities their ownership into Bolton Real Estate and the conditions in which such registered shares have been sold to Attica Eesti OU, as well as it is unclear whether or not Maria Elisabeth Planting, Sam Arvid Mikael Planting and Bettina Margaretha Sandboge have declared to the Finnish Tax Authorities their ownership into Attica Eesti OU.
Note #7 :
The Finnish Citizen Ari Tapio Lehtoranta (DOB 22.04.1963) was, from June 2006 to September 2006, a direct shareholder of Bolton Real Estate, in an amount of 1 560 000 EEK (around 100 000 €). Since this date, it is the Estonian company Hisra Investment OU (Valge 13, reg. number 11299054), which is the owner of these registered shares (registered value as of today of 237 012 €). Hisra Investment OU (capital of 50 000 EK ie around 3 000 €) has for sole shareholder Ari Tapio Lehtoranta.
It is unclear whether or not Ari Tapio Lehtoranta has declared to the Finnish Tax Authorities its initial ownerhip into Bolton Real Estate or the financial conditions in which such shares have been transferred to Hisra Investment OU, just as it is unclear whether or not Ari Tapio Lehtoranta has declared its ownership withing Hisra Investment to the Finnish Tax Authorities.
- B. Use of bogus Estonian companies to either reduce the tax liability of Finnish companies (through deduction from investments or goods or services invoiced) or to improve the financial results of the Finnish companies (through integration of a fake value of assets or fake profit)
The Finnish company IPON COMMUNICATIONS OY, register number 1847651-7., former subsidiary of Setera OY (register number 1947771-4.) and now merged with Setera OY, is a shareholder of the company HELINA TELEKOM OU (Valge 13, register number 11040379). This company, which is failing since two years to report its financial results and is having a tax debt to the Estonian Tax Office, is supposedly delivering Voice Over IP telecom services (same activity as IPON COMMUNICATIONS OY).
In fact, Helina Telekom OU, which has no technical resources, and no human resources beyond its director (Mirjam-Mari Marastu, Estonian Citizen with the profession of Lawyer), is completely unable to deliver such services.
As a result, any invoicing from HELINA TELEKOM OU to either IPON COMMUNICATIONS OY, SETERA OY, or VODACOM OY (registered 2101809-0 before being merged with SETERA OY) would have been completely fictious and would have had for only motivation to reduce the tax liabilities of these companies.
As well, any revenue consolidated by IPON COMMUNICATIONS OY from “activities” of HELINA TELEKOM OU would be fictious, just as any “investment” made by IPON COMMUNICATIONS OY into HELINA TELEKOM OU would be fictious.
- C. Possible use of bogus Estonian companies to invoice fictious goods or services to Finnish companies and / or to invoice customers of the said Finnish companies on behalf of these Finnish companies (and/or collect funds from invoicing issued by these Finnish companies to their customers) in order to reduce the tax liability of the said Finnish companies.
It is highly probable that EMCON OU (Valge 13, reg number 11388473), managed by Juha Ossi Kajavuori and Eero Olavi Makkonen, director of EMCON OY (1965554-1) is either invoicing for fictious services its mother company, or invoicing customers for goods or services which are in fact delivered by EMCON OY.
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