Advance ruling on corporate taxation matters

The Tax Administration can grant advance rulings on taxation matters that concern your company. An advance ruling specifies our tax assessment procedures for the matter in question. 

Examples of matters for which a foreign corporate entity may request an advance ruling:

Example: A foreign company hires an employee in Finland. The employee coordinates sales and works in a client company’s facilities. The company asks if this means that it has a permanent establishment in Finland.

Example: A foreign investment fund purchases shares of a Finnish real estate holding company and receives income from Finland for these shares. The fund asks if it is comparable to a Finnish investment fund and whether it is liable to pay tax to Finland on its income.

Example: The permanent establishment of a foreign company transfers its business to a new limited company. The company asks if the regulations on transfer of business in the act on the taxation of business income (Laki elinkeinotulon verottamisesta 360/1968) are applicable to business restructuring.

Example: A non-resident corporate entity outside Finland will receive dividend income for the shares of Finnish listed companies that it owns. The corporation asks if it is comparable to a Finnish corporate entity in accordance with § 20 of the act on income tax (Tuloverolaki 1535/1992), in which case the dividends would be exempt from tax.

How to request an advance ruling

If you have a Katso ID, you can request an advance ruling in MyTax.

Request an advance ruling in MyTax

See instructions for MyTax

If you do not have a Katso ID, you can send us a free-form request written in Finnish or Swedish. The request must specify the following:

  • the tax matter for which you are requesting an advance ruling
  • the grounds for requesting the advance ruling
  • the tax years which the requested advance ruling concerns.

Include with your written request

  • a cover page (7300)
  • all required additional clarifications. The additional clarifications and other attachments can be in English. We will ask you to provide translations of the documents if necessary.

Request an advance ruling before the deadline 

If you are requesting an advance ruling on an income tax matter, make your request before the income tax return’s filing deadline. If you have been granted an extension for the deadline, follow the extended deadline.

If you are requesting an advance ruling concerning other tax types, such as tax at source, make your request before the filing deadline of the tax in question or the due date of the prepayment in question.

You will receive a decision on the advance ruling

The Tax Administration will provide a written decision on your request. The decision is subject to a charge. You will receive a notification of the decision by post. The decision will only be available in Finnish and Swedish.

List of fees charged for certain Tax Administration services (available in Finnish and Swedish, link to Finnish)

Appealing against an advance ruling

You can appeal an advance ruling to the Administrative Court. The appeal period is 30 days after receiving notice of the decision.

More detailed instructions on appeal are included with the advance ruling.

A decision in which the Tax Administration decides not to grant an advance ruling cannot be appealed against.