How to appeal against a decision on self-assessed taxes

Companies and organisations can claim adjustment of a decision on self-assessed taxes, such as VAT, excise duties or employer's contributions. Employer's contributions include the tax withheld on wage payments and the employer's health insurance contribution.

Decisions on self-assessed taxes include the following:

  • tax decision
  • decision on adjusting a decision
  • decision on punitive tax increase
  • decision on late-filing penalty
  • decision on a refund request
  • decision on authorisation
  • registration decision.

This guidance concerns all companies and organisations.

Read more about appealing against a decision on registration.

Submit a claim of adjustment to the Assessment Adjustment Board

You can appeal against a decisionby filing a claim for adjustment with the Assessment Adjustment Board. Instructions for appeal are enclosed with the decision. Instructions for claiming adjustment of the late-filing penalty are enclosed with the tax summary.

If you had a special reason for filing your tax return late, you can also request that the Tax Administration should not charge the late-filing penalty. Read more about the late-filing penalty.

Check the due date for appeal and read the instructions for appeal enclosed with the decision.

How to appeal?

Make a claim for adjustment in MyTax

You can also file the claim for adjustment on paper. State your claim by filing a free-form written account. You can enclose the form Claim for adjustment of self-assessed taxes (Form 4015e) as a cover page.

A fully free-form claim for adjustment can also be filed.

The claim for adjustment must always contain the following information:

  • the appellant's name and Business ID
  • the decision appealed against
  • how you want the decision to be adjusted
  • the grounds for claiming adjustment.

Remember to sign the claim for adjustment if you file on paper. If the claim is signed by an agent rather than the appellant, enclose a power of attorney. In addition, you must enclose the documentation you want to refer to.

When must the appeal be filed?

A claim for adjustment must usually be filed within 3 years. The period of appeal starts at the beginning of the year following the end of the tax period.

However, if the company’s or organisation’s accounting period is not the calendar year but the tax period is the calendar month, the period of appeal starts at the beginning of the year following the end of the accounting period.

In any case, the appeal period is always at least 60 days. The 60-day period begins on the date when the company or organisation is notified of the decision.

A claim for adjustment of a registration decision, authorisation decision or another special decision must be submitted within 60 days from the date when the company or organisation was notified of the Tax Administration’s decision. In this case, the period of appeal is much shorter than the generally applied period of 3 years.

Always check the due date for appeal in the instructions for appeal enclosed with the decision.

Example 1: A company’s accounting period is the calendar year. The company’s VAT period is one month. The due date for claiming adjustment of a decision concerning the tax period 1–30 June 2020 is 31 December 2023.

Example 2: A company’s accounting period is the calendar year. The company receives a decision on excise duties for the tax period 1–30 November 2021. The Tax Administration issues the decision on 31 January 2022. A claim for adjustment must arrive at the Tax Administration by 31 December 2024.

Example 3: A company has two accounting periods ending during the same calendar year: 1 July 2021–30 June 2022 and 1 July 2022–31 December 2022. The company’s tax period is the calendar month. The company can claim adjustment of tax decisions concerning these periods until 31 December 2025.

Example 4: On 11 January 2021, a company was notified of a decision on an authorisation. A claim for adjustment must arrive at the Tax Administration by 12 March 2021.

Note the transition periods

Excise duties are considered self-assessed taxes as of 2021. Follow the instructions on this page if the excise duty decision you have received

  • concerns a tax period that started on or after 1 January 2021
  • was made on or after 1 February 2021 and the tax period (or other liability for tax) ended before or in 2020
  • concerns a refund request submitted on or after 1 January 2021
  • is a decision on authorisation or registration and was issued on or after 1 January 2021.

If the decision concerns employer's contributions and the tax period ended before or in 2016, the period of appeal is 5 years. The period of appeal starts at the beginning of the calendar year following the date of decision.

Claims submitted late will not be processed

A claim for adjustment must arrive at the Tax Administration by 4.15 pm on the due date of appeal. The Tax Administration will not process claims that arrive late.

Decisions are in force even if an appeal is pending

A company or organisation appealing against a decision must still comply with the decision until the claim for adjustment or the appeal has been processed.

However, they can request suspension of the collection of tax. The suspension of collection means that the enforced recovery of the tax is interrupted until the appeal has been processed.

Read more about interruption of enforced recovery

Appeals to the Administrative Court and the Supreme Administrative Court

A decision on a claim for adjustment can be appealed to the Administrative Court. The appeal must be submitted within 60 days from the date when the appellant was notified of the decision. In excise taxation, the period of appeal applies to decisions made by the Assessment Adjustment Board.

Check the due date for appeal and read the instructions for appeal enclosed with the decision.

A decision by the Administrative Court can be appealed to the Supreme Administrative Court if the Supreme Administrative Court grants a leave for appeal. Appeals to the Administrative and Supreme Administrative Courts may be subject to a charge.

Read more about the charges and check the address details of the Administrative Courts (oikeus.fi). Read more about the charges and check the address details of the Administrative Courts (oikeus.fi).