Supreme Administrative Court decision: fees paid to food couriers are wage income

The Supreme Administrative Court’s decision of 13 May 2026 on food couriers’ income taxation introduces a change to the previous tax assessment practice. According to the Supreme Administrative Court’s decision, when a courier company pays for deliveries to a general partnership, the fee paid is wage income to the partner who made the delivery.

Last year, on 22 May 2025, the Supreme Administrative Court issued a preliminary ruling on the labour law status of food couriers (KHO 2025:41). According to the ruling, food couriers have an employment relationship to the courier company, i.e. they do not work as independent entrepreneurs. On 19 March 2026, the Supreme Administrative Court rejected the application for reversal of the ruling filed by a courier company. 

The Supreme Administrative Court’s decisions change the tax assessment practice applied to food couriers

On account of the Supreme Administrative Court’s decisions, the Tax Administration will change its directions regarding food couriers’ tax assessment and use of invoicing service companies. The new directions will be applied in tax assessment as of 1 January 2027.  

Up until now, food couriers have been in an employment relationship or a commision relationship from the point of view of taxation, depending on the agreement made between the food courier and the food courier company. Food couriers in an employment relationship have received wages, whereas those in a commission relationship have received trade income (non-wage compensation for work).

Further, it has been acceptable for food couriers working in a commission relationship to invoice through an invoicing service company. The invoicing service company has paid the amount received from the courier company to the food courier either as wages or as trade income, depending on the agreement made between the invoicing service company and the food courier.

The amount received by a food courier will be treated as wage income from a courier company

According to the Supreme Administrative Court’s decisions, food couriers have an employment relationship to the courier company, i.e. they do not work as independent entrepreneurs. This applies to all food couriers, including those who have acquired a Business ID and worked as food couriers in the capacity of a business name entrepreneur or a shareholder of a partnership or limited liability company.

Payments from a food courier company are the courier’s taxable wage income, and the courier company must therefore withhold tax and pay the employer's health insurance contribution on the amount. If the courier company allows the use of substitutes, any payments to the substitute are also wage income earned in an employment relationship, and the courier company must fullfil the related employer obligations.

As the employer, the courier company is also responsible for any other employer obligations, such as taking out statutory insurance policies for its employees. 

Food couriers need tax cards for wages

The courier company must withhold tax on wages at the rate indicated on the food courier’s tax card for wages and also pay the employer's health insurance contribution. The courier company can reimburse its food couriers for work-related travel expenses exempt from tax, provided that the courier presents a travel expenses statement and that the conditions according to the Tax Administration’s decision on expenses are met.

Food couriers can no longer use an invoicing service

According to the Supreme Administrative Court’s decisions, food couriers are in an employment relationship according to the Employment Contracts Act to a courier company, and therefore they can no longer invoice their wage income, trade income or travel expenses through an invoicing service company. 

Further information

Supreme Administrative Court decision KHO 1304 issued on 13 May 2026 (available in Finnish)

Supreme Administrative Court decision KHO:2025:41 (available in Finnish and Swedish, link to Finnish)