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These instructions are for nonresident foreign corporate entities. A foreign corporate entity is considered a resident taxpayer in Finland if it's place of effective management is in Finland. Read more about the place of effective management and a tax resident corporate entity’s tax obligations.
A foreign company's operations in Finland may give rise to a permanent establishment in Finland in income taxation. In this case, the foreign company is liable to pay income tax to Finland on all income attributable to this permanent establishment.
A permanent establishment is a fixed place of business, through which the business of an enterprise is wholly or partly carried out. If the company has a fixed place of business in Finland that falls into one of the following categories, a permanent establishment may be formed:
A place of business can be considered a permanent establishment only when it is established at a distinct geographical place with a certain degree of permanence.
Example: A Lithuanian shipbuilding company comes to Finland to work at a shipyard. The company works at the shipyard’s premises for a year. The company is considered to have a fixed place of business at the shipyard through which it operates its business. The company is therefore considered to have a permanent establishment in Finland.
A foreign company may be treated as having a permanent establishment in Finland if the company's management and business administration are managed in a fixed place of business in Finland. A place of management can be located, for example, in the premises of another enterprise or at the home of a company director.
A place of management which gives rise to a permanent establishment has a different definition than a place of effective management which makes the foreign corporate entity a resident taxpayer in Finland. Read more about drawing the line between the place of effective management and the place of management that gives rise to a permanent establishment.
A site where a construction, installation or assembly operation is performed may give rise to a permanent establishment. A permanent establishment is formed in these situations, unless the tax treaty between Finland and the country of the foreign company's tax residence restricts Finland's taxing rights. For example, under the tax treaty between Finland and Estonia, a construction project that lasts longer than 6 months gives rise to a permanent establishment.
A site usually exists from the date when the contractor begins its work, including any preparatory work, in the country where the construction is to be established. A site continues to exist until the work is completed or permanently abandoned. Normally, interruptions when the work is temporary discontinued are included in the duration of a project.
If a foreign company has several projects in Finland, each one of them should be treated separately in terms of the time limit. However, if various projects form a coherent whole commercially and geographically, the projects could be considered as a single unit and the durations could be summed together.
Example: An Estonian construction company comes to Finland to work on a building project that starts on 1 February 2025 and ends on 31 October 2025. However, the project is halted for two months between 1 May and 1 July 2025 due to material shortages. Temporary interruptions are included in the total length of the project. The company is therefore considered to have a permanent establishment at the location of the site.
A foreign company may have a permanent establishment in Finland if it has a representative or agent working in Finland, even if no permanent place of business is available to the company.
If the representative is a dependent agent, the representative’s operation may give rise to a permanent establishment in Finland if the representative has the authority to enter into contracts or receive orders on behalf of the foreign company. In addition, for a permanent establishment to be formed, the representative must regularly enter into contracts or receive orders. The definition dependent agent includes companies and natural persons, such as a company employee, who sells the foreign company's products or services in Finland.
The operations of an independent representative do not give rise to a permanent establishment. An independent representative is both financially and legally independent from the foreign company. Typically, intermediaries, brokers and commission agents are independent representatives.
Preparatory and auxiliary activities do not give rise to a permanent establishment. For example, advertising, collection of information, supply of information, scientific research and maintenance of a stock of goods or merchandise belonging to the enterprise for the purpose of storage, display or delivery may fall within activities of preparatory or auxiliary character.
A case by case analysis of the actual circumstances of the conducted business activities must be made in order to determine whether the activities are of preparatory or auxiliary character. Activities cannot be considered preparatory or auxiliary if they make up an essential and significant part of the activity of the foreign company as a whole, or if they make up a business unit of their own.
A foreign corporate entity must file a tax return on its taxable income and deductible expenses if at least one of the following conditions applies.
The foreign corporate entity has:
Foreign corporate entities must also file a tax return if the Tax Administration requests it.
Foreign corporate entities must file the tax return Form 6U and any attachments electronically. Read the instructions for completing Form 6U carefully before filing the tax return. There are several ways to file the tax return electronically:
If you wish to add an attachment to your tax return after filing it, but there is no need to make changes to the tax return itself, only submit the new attachment. Do not submit the tax return again.
The tax return can be filed on paper only if there is a special reason, for example, if electronic filing is impossible due to technical difficulties.
A representative of a foreign corporate entity needs to have a Finnish personal ID or a UID and a Suomi.fi authorisation in order to use the Tax Administration’s e-services on behalf of the company. When you have an UID identifier and an authorisation, you can log in to the e-services with the Finnish Authenticator app and submit the tax return and any attachments electronically. Read more about obtaining a UID identifier and an authorisation.
A foreign corporate entity uses the tax return Form 6U to report the revenues, expenses, assets and liabilities of its permanent establishment. The section 'Calculation of taxable income (Business Tax Act)' is for reporting the business income and costs of the permanent establishment. Also, the withheld tax-at-source on the company's trade income must be filed on the tax return. The section 'Calculation of net worth' is for reporting the assets and liabilities of the permanent establishment.
Even if a foreign corporate entity does not have a permanent establishment in Finland, it is usually obligated to pay tax on the income it receives from real estate and housing-company apartments located in Finland. Income and expenses related to these are also submitted on Form 6U.
Photocopies of the permanent establishment's profit-and-loss account and balance sheet must be enclosed with the tax return. The profit-and-loss account and balance sheet must be drawn up as required by the Finnish Accounting Act.
More information:
The tax return must be filed within four months after the end of the calendar month in which the company's accounting period ends. The accounting period of the permanent establishment of a foreign corporate entity is the same as the accounting period of the head office.
Example: The accounting period of a limited liability company ends on 15 March 2026. The company must file its tax return by 31 July 2026. If the final deadline is a Saturday or holiday, the filing deadline is extended to the next working day.
The tax return can be filed on paper only if there is a special reason, for example, if electronic filing is impossible due to technical difficulties. If the tax return is filed on paper, it must arrive at the Tax Administration by 4.15 pm on the due date.
A late-filing penalty is imposed if the tax return is filed after the deadline but before the company’s tax assessment has been completed. A late-filing penalty is also imposed if additions or corrections are made to the tax return on the company’s initiative after the filing deadline but before the completion of tax assessment. The amount of late-filing penalty is €100. Read more about penalties in income taxation (in Finnish and Swedish).
If the foreign corporate entity believes its business activities in Finland do not give rise to a permanent establishment for income tax purposes, it must state this in section 2 of Form 6U and enclose a completed Form 80 (Account of local operations - Foreign corporate entity). All foreign corporate entities operating in the construction, installation and assembly sectors must report their operations and contracts in Finland with Form 80 every year.
The tax return with the attached form 80 must be filed within four months from the end of the month in which the accounting period ends.
The tax return and Form 80 do not need to be filed if the foreign corporate entity has received a binding advance ruling from the Tax Administration stating that it is not considered to have a permanent establishment in Finland. However, if there have been any changes in the corporate entity's operations or if the Tax Administration has requested it to provide more information, the entity must file a tax return with Form 80.
You can check the current stage of the processing of your tax return in MyTax. Once you are logged in, you can look up the stage on the front page under Payment status.
The Tax Administration confirms the final amount of income tax for the fiscal year based on the filed tax return.
The tax assessment decision is sent to the foreign corporate entity after the Tax Administration has processed the information on the tax return and completed the tax assessment process. The tax assessment decision provides the amount of tax refund or tax to be paid (residual tax).
Every taxpayer has its own end date for tax assessment which is stated on the tax assessment decision. However, for foreign corporate entities, the assessment will end no later than 10 months after the end of the last calendar month of the accounting period.
If more than one accounting period has ended during the calendar year, the end date of assessment is no later than 10 months after the end of the month when the most recent accounting period ended.
After completing of the assessment process, the Tax Administration sends the decision letter to the foreign corporate entity.
Example: The accounting period of a corporation is 1 January 2025 to 31 December 2025. The assessment process will end on 31 October 2026 at the latest.
Example: The accounting period of a corporation is 1 April 2025 to 31 March 2026. The assessment process will end on 31 January 2027 at the latest.
The tax assessment decision may change before the end date of the assessment procedure, if the foreign corporate entity sends additional information or corrects the tax return, or the Tax Administration informs the entity that the assessment procedure is still ongoing. The Tax Administration sends a new tax assessment decision in these situations. The final result of the tax assessment is shown on the most recent decision letter.
Read more about paying the residual tax (in Finnish and Swedish).
Key terms:
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