Work done by foreign leased employees

When leased employees coming from a foreign country perform work in Finland or on board a Finnish vessel or aircraft, the party that ordered the work may have to submit a report with the names and identities of the foreign leased employees who did the work, and to withhold tax at source on the trade income paid.

The party ordering the work must file a report on leased work

If you are a Finnish company, a Finnish individual or a foreign company with a permanent establishment or a place of effective management in Finland, you are required to report information when you have leased employees from a leasing agency. As the party ordering the work, you are the hirer i.e. the service recipient, and you must provide information on every foreign company that you had leased employees from.

In situations where Finland is the place where work is done, the service recipient must submit a report on leased work, if the tax treaty between Finland and the leased employee’s country of fiscal residence contains a provision laying down that Finland can levy income tax on a leased employee’s pay starting on the first day of work. As the service recipient, you must also submit the report if the leased employee’s country of residence is a country that does not have a tax treaty with Finland.

If the leased employee is from one of the following countries, a tax treaty gives Finland the right to tax their pay:

Estonia, Latvia, Lithuania, Sweden, Norway, Denmark, Germany, Iceland, Moldova, Georgia, Belarus, Isle of Man, Guernsey, Bermuda, Jersey, Poland, Kazakhstan, Cayman Islands, Turkey, Cyprus, Tadzikistan, Turkmenistan, Albania, and Spain.

Starting 2026, when you are the Finnish-based service recipient, you must additionally submit a report on leased work if a leased employee works for you on board a Finnish vessel or aircraft.  However, if Finland has a tax treaty with the leased employee’s country of residence that prevents Finland from levying tax on the employee’s wages, you are not required to submit the report.

The report to the Tax Administration on leased work (Työn teettäjän ilmoitus ulkomaisen vuokratyön käytöstä) must be submitted when a leased employee has performed work on board a Finnish vessel or aircraft, after 1 January 2026, regardless of the point in time when the leased employee had started working there. This means that the report must be submitted concerning work done after 1 January 2026 even if the leased employee started working in 2025, for example, or even if he or she had started working before 2025.

In accordance with the rules above, the employee's country of residence will determine which country has the taxing rights and to where tax returns and other reports must be filed. The foreign leasing agency’s country of residence or domicile is of no importance.

You can submit the required report in MyTax.

Alternatively, you can complete Form 6146 – "Report submitted by the hirer of leased employees" (Vuokratyön teettäjän ilmoitus ulkomaisen vuokratyön käytöstä / Inhyrarens anmälan om användning av hyrd utländsk arbetskraft).

You must submit it by the end of the calendar month following the month when you had the first foreign leased employee doing work for you. You must give these details regardless of the duration of the lease or the number of days you had the leased employees.

If there are any changes to the details you have given on Form 6146 (such as change of address, or termination of an activity), you must log in to MyTax to submit an update, or if you use the paper Form 6146, send an updated form to keep us up to date.  

The deadline for sending the update form is the end of the calendar month after the month when the changes occurred. However, you do not have to notify us if you just have a temporary break in your operations.  You are considered to have terminated your leasing operation if you do not lease any employees from the foreign agency to work for you for a period of six months.

If you do not submit the report, or if you submit it late, you may have to pay a penalty for negligence of up to €15,000.

The service recipient’s obligation to withhold tax at source 

When you are the service recipient, you must withhold tax at source on the payments of trade income that you make to the foreign leasing agency that has provided you with leased employees. The rate is 13% if the foreign leasing corporation or agency is a limited-liability company, another type of corporate entity, or a partnership. If the leasing agency is operated by a self-employed individual, the rate is 35%. You don't have to withhold the tax- at-tax at source if the leasing agency – either a foreign corporation or a foreign self-employed individual – is on the Finnish prepayment register, or has shown you a tax-at-source card with the zero withholding rate or other documentation proving that withholding is prevented.

However, it is not enough for the foreign leasing agency to show you the above documentation if you are paying for work within the construction industry, for work related to an assembly or installation project, for work related to transportation services, or for work related to cleaning, nurse services or medical treatment or if you are paying for employee leasing with regard to these sectors of activity. When work or services falling into the above categories is involved, you must withhold the source tax unless you are paying to a leasing agency that has a Finnish prepayment registration or to an agency that had presented its tax-at-source card to you indicating a 0% rate of withholding. 

If you lease employees to work for you, you may also have other obligations and duties in addition to the ones described here. For more information, visit the website of the Occupational Safety and Health Administration.