International exchange of information on natural persons between tax authorities Detailed guidance

This is an unofficial translation. The official instruction is drafted in Finnish (Luonnollisia henkilöitä koskeva kansainvälinen tietojenvaihto veroviranomaisten välillä, record number VH/1418/00.01.00/2026) and Swedish (Internationellt utbyte av information om fysiska personer mellan skattemyndigheterna, record number VH/1418/00.01.00/2026) languages.

These instructions discuss the exchange of income tax information on natural persons between the tax authorities of Finland and other countries. No information exchange activities concerning for example value-added taxes nor excise duties are addressed here because they fall outside of the scope of this guidance.

This version of the instruction was updated to accommodate the recent changes to the Directive (EU) 2023/2226 (often called DAC8), and to address the reporting rules on preliminary rulings (as set out by the DAC3 Directive) and the reporting rules on cross-border arrangements (DAC6). The guidance on automatic exchange of information was rewritten for this version. In addition, this version also describes the changes made to section 56b of the Act on assessment procedure, going into effect at the beginning of 2026.

1 General information about international cooperation and exchange of information

The international exchange of information is part of the cross-border administrative cooperation between the tax authorities of different countries. Alongside the exchange of information, other means of cooperation include the presence of officials in the administrative agencies of other Member States, participation in administrative investigations, and simultaneous audits.

In addition to a valid treaty or a Directive or Regulation on cooperation being in force, to co-operate successfully requires confidential relationships and safe procedures, and a degree of reciprocity of the activities that are conducted. Because the participating countries use a shared layout of fillable forms, standard formats of data interchange and protected web connections, for example, they can attain a better adherence to the original purpose of information exchange, a sufficient quality level and compliance with requirements on data security.

The goal of information exchange is that the income of an individual or corporate entity operating or having operated in two or more countries would be taxed correctly and at the correct amount in each country.

EU law and international treaties between two or more countries contain detailed rules on international exchange of tax information. Accordingly, the legal basis of information exchange consists of:

• The Nordic Convention on Mutual Administrative Assistance in Tax Matters (37/1991)
• The Convention on Mutual Administrative Assistance in Tax Matters (21/1995)
• Council Regulation (EU) No 904/2010 on administrative cooperation and combating fraud in the field of value added tax (regulation on administrative cooperation)
• Directive 2010/24/EU concerning mutual assistance for the recovery of claims relating to taxes, duties and other measures
• Directive 2011/16/EU on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC (on administrative cooperation), and the Directives on its amendments, extending mandatory automatic exchange of information
•  Bilateral agreements including the FATCA agreement (25/2015)

In addition, provisions on information exchange are included in many of the income tax treaties that Finland has signed with other countries. In addition, Finland has entered into certain limited tax treaties that facilitate the exchange of information, as well. For more information on the limited treaties, see the list of Finland’s tax treaties in force on the vero.fi website. In addition to the above, Finland has approximately 40 agreements on exchange of information that facilitate the exchange of tax-related information on request.

Information is only exchanged between the competent authorities appointed to the task in each country. The implementing regulation on the Directive on administrative cooperation defines the Tax Administration as Finland’s competent authority in the area of income taxes. If an authority authorised or appointed by the Ministry of Finance can be the competent authority in accordance with a certain agreement, the Tax Administration has been named Finland’s primary competent authority. Provisions to this effect are laid down in section 88 of the Act on assessment procedure (Verotusmenettelylaki (1558/1995)). The Ministry of Finance can, however, examine and resolve a matter deemed to be important as a matter of principle. The tasks relating to international exchange of information at the Tax Administration is the responsibility of competent officials appointed accordingly.

In general, any information received through information exchange can only be used for a purpose related to implementation and administration of national fiscal legislation. However, the EU directive on administrative cooperation, for example, contains provisions that allow for information being used for other purposes as well, if the national laws of both Member States enable this, and if the competent authority in the sending Member State had permitted such use. If the information is, without restriction, used for similar purposes in the sending Member State, the competent authority in the sending Member State is under obligation to give the permission.

The international exchange of information can be divided into three groups: automatic, spontaneous, and exchange of information on request. These three main groups are discussed in more detail in the following sections. 

2 Automatic exchange of information 

Automatic exchange of information means an exchange of information that concerns a large group of taxpayers at once, requiring no express request on the receiving country’s part, is taking place on a regular basis, and implements a standard predefined format.

To initiate an automatic exchange of information requires not only a valid treaty, but also a bilateral or multilateral agreement between the competent authorities based on the treaty. Between the Member States of the European Union, to exchange information automatically is controlled by the provisions of a Directive or Regulation.

In its role as Finland’s competent authority, the Tax Administration sends out predefined sets of information concerning the income taxes of individual taxpayers (natural persons) to the competent authorities of each country once a year. Regarding the tax year that had ended, the set of information concerns all individuals who – according to the Tax Administration’s records – reside in the receiving country and had received income sourced to Finland during the year, or who own certain assets in Finland, such as immovable property or a bank account. The Tax Administration, in turn, will receive information on Finnish resident individuals concerning their income received from sources in the sending country, or concerning the assets and property they own in the sending country. From time to time, the process of automatic information exchange also involves some remedies of errors, i.e. the making of multiple corrections to previously submitted information that needs to be changed or removed.

Finland sends out information mostly collected from third-party payers, and from other third-party filers of reports, including financial institutions. Predominantly, sources of the Finnish information consist of the reports submitted by third parties to the Incomes Register on payments to nonresidents, of the received annual information on other categories of payments to nonresidents, and of the more special annual information returns that satisfy an express requirement on collection of tax-related information. Another source of information is our database of tax assessment: for example, we may use the details given by an individual taxpayer on their income tax return. The Tax Administration uses this information to collect tax data on residents of other contracting states and to generate the files for sending to the relevant countries.

2.1 Certain categories of income and assets

The Multilateral Convention on Mutual Assistance in Tax Matters of the EU and the OECD was prepared in 1988 and was enforced in Finland by a decree on 1 April 1995. The revised convention entered into force in 2011, and it has been signed by more than 140 countries or jurisdictions. The countries party to the convention can exchange information and engage in co-operation in tax matters including administrative assistance in the collection of taxes. Information is exchanged automatically on the categories of income as determined in the OECD Model Tax Convention’s articles on income. No deadlines are set for the activity of information exchange. Normally, we send out information from Finland by the end of June, the year following the tax year.

Since the beginning of 2014, the Directive on administrative cooperation (2011/16/EU, the DAC1 directive) has been applied between EU Member States. The member states are under a duty in accordance with the DAC1 Directive to send out automatic information concerning the income received, and investments held, by residents of other member states, and to break down the information into the following categories: income from employment, director’s fees, pensions, holdings of life insurance products, and holdings of immovable property and information on the income derived from the immovable property. The 2014 tax year was the first year when the above requirement was in force. As of tax year 2023, royalties were added to the above categories. The content of the information to be exchanged should be based on data collected for tax purposes in each member state, and the information’s structure should comply with the agreed data formats created through co-operation between member states. Information must be exchanged at least once a year, within six months of the end of the member state’s tax year during which the information became available.

For the most part, Finland sends its information for the latest tax year by the end of June, insofar as the information can be collected from the different sources that are available, such as reports received by the Incomes Register concerning paid amounts to nonresi¬dent taxpayers, and other sources. It should be noted that the information relating to immovable property constitutes an exception, because this information is not reported to the Incomes Register. As a result, Finland cannot send it until the stage is reached when the assessment of all taxpayers’ taxes for the tax year is complete.

As for the exchanged information arriving here, the information collection schedules of the sending country are known to affect the times of delivery and receival greatly.

2.2 Financial account information 

Exchange of financial account information based on the FATCA agreement started with the United States in 2015 regarding information on accounts existing in the 2014 tax year. In September 2017, Finland began a similar exchange also with EU Member States. The first financial account information concerned the 2016 tax year. The legal base of the exchange of information in the European Union is the amended DAC2 Directive (2014/107/EU), which determines the reporting entities, their obligations and the information to be collected for the purpose of automatic information exchange. When financial account information is exchanged with countries outside the European Union, the legal base is either the multilateral Convention between competent authorities on the automatic exchange of information on financial accounts or a bilateral treaty. Both for EU and non-EU countries, we use the data formats of the Common Reporting Standard, CRS, developed by the OECD.  At present, some 120 countries around the world participate in information exchange.

Financial institutions having the information-reporting requirement in Finland need to submit an annual information return to the Tax Administration for this purpose. After the returns arrive, the Tax Administration generates data files that contain the financial account details, which are then itemised country by country, for sending to the tax authority of each country. The content includes the person’s gross income in the financial account, which consists of receipts of interest, dividends and other income connected to the bank balances in his or her financial account maintained by the reporting financial institution. Additionally, the financial institutions need to indicate the end-of-year balance or alternatively, declare that the financial account was closed during the year that ended. The reporting in the framework of FATCA has a somewhat less extensive content of information. The point in time when the majority of financial account information is exchanged is the end of September the year after the reportable year.

For more information on exchange of financial account information, see the Tax Administration’s detailed guidance “Application of the FATCA agreement on the exchange of tax information between Finland and the USA” — Verohallinnon ohje Suomen ja Yhdysvaltain välistä verotietojen vaihtoa koskevan FATCA-sopimuksen soveltamiseksi, and “Application of the Act to enforce the DAC2 Directive and the provisions of § 17b, § 17c and § 17d of the Act on assessment procedure” — Verohallinnon ohje ns. DAC2-direktiivin voimaanpanolain sekä verotusmenettelylain 17 b, c ja d -§:n soveltamiseksi (both available in Finnish and Swedish).

2.3 Preliminary rulings

The Directive on Administrative Cooperation was amended in 2015 by the DAC3 Directive (2015/2376/EU).

Under the DAC3 provisions controlling exchange of information, information to be sent to other countries should additionally include preliminary rulings and advance pricing agreements issued to companies and other corporate entities. As a result of the latest amendment to the Directive, the DAC8 (2023/2226/EU), exchange of information will extend to preliminary rulings issued to natural persons when the value of one transaction or a series of transactions involving cross-border dealings exceeds €1,500,000, or if the preliminary ruling directly establishes the tax residency of the person in the Member State of issuance, with certain exceptions. The exchange of information on natural persons concerns preliminary rulings issued, amended or renewed on 1 January 2026 or later.

For more information, see the Tax Administration’s instructions “International exchange of information in matters of preliminary rulings and advance pricing agreements” — Ennakkopäätöksiä ja ennakkohinnoittelusopimuksia koskeva kansainvälinen tietojenvaihto (in Finnish and Swedish).

2.4 Specific cross-border tax arrangements to be reported

The Act on reportable arrangements (Laki raportoitavista järjestelyistä verotuksen alalla (1559/2019)) is in force since 1 January 2020. Also in 2020, new provisions were added to the Act on assessment procedure on a service provider’s information-reporting requirement and on a reporting obligation that concerns the taxpayer. The new provisions and legal norms served the purpose of implementing the reporting obligation on certain cross-border tax planning structures as required by the Directive on administrative cooperation, which has amended the DAC6 Directive (2018/822/EU). The amended Directive is set to improve access to information by tax authorities in EU Member States on cross-border tax arrangements, which might contain various elements of tax evasion or avoidance. A person participating in a reportable arrangement may be a natural or legal person, or any legal arrangement.

The Directive imposes an obligation on EU Member States to collect facts and information concerning reportable cross-border arrangements from those subject to a reporting requirement. In addition, in certain circumstances, the party liable to report information may be the taxpayer themselves.

The party must submit the information to the Tax Administration in a data format prepared for this purpose (DAC6 – Report on a reportable arrangement). These reports must be submitted within 30 days of the point in time when an arrangement has exceeded the reporting threshold. The Tax Administration will then forward them, on a quarterly basis, to a central register maintained by the European Commission. The central register will transmit the information further, to the tax authority of the Member State affected by the reported information.

For more information, see the Tax Administration’s detailed guidance Reportable cross-border arrangements. Section 5 of the guidance contains descriptions of situations where the responsibility for submitting a report on a reportable arrangement lies with the taxpayer.

2.5 Rental contracts and sales transactions facilitated by digital platforms

Based on the DAC7 Directive for amending the Directive on administrative cooperation (2021/514/EU), all EU Member States have since 2023 been required to collect data on sales of goods and services, and to collect data on rental contracts involving immovable property and means of transportation, by natural persons and entities, through facilitation effected by a digital platform. This type of exchange of information within the EU started in 2024 with the information that was reportable for the 2023 calendar year.

Accordingly, platform operators in Finland must send information to the Tax Administration by the end of January of the year after the reporting year. They need to use a data format for an annual information return designed for this purpose. The information exchange between EU Member States, in turn, is scheduled for the end of February. When information is being exchanged, the Tax Administration sends the information to the Member State of residence of the person to whom the income is paid through the digital platform. If rentals of real estate or other immovable property were facilitated by a platform, the information would additionally be sent to the country where the property is located. Other EU Member States send information to the Tax Administration on the income, facilitated over a platform, received by Finnish resident individuals and companies. Likewise, they send us information concerning immovable property located in Finland and rented through a platform.

From the beginning of 2026, the information exchange will be extended to countries outside the EU that activate an agreement on exchange of information with Finland. This means that starting the 2026 reporting year, platform operators must also collect data on sellers whose country of residence has an active agreement on exchange of information with Finland. The extent of data collection will vary by what is laid down in the agreements signed with those countries. Platform operators will need to send the information to the Tax Administration for the first time by the end of January 2027, and the Tax Administration will send it on to foreign tax authorities by the end of April 2027.

For more information on the information-reporting requirement of platform operators, see the Tax Administration’s guidance The information-reporting requirement of a Reporting Platform Operator (DAC7).

2.6 Exchanges and transfers with crypto assets

The Crypto-Asset Reporting Framework (CARF) imposes a requirement to collect data on crypto asset users and the transactions made. This means that the companies that offer crypto asset services to third parties need to collect the data. Having done so, the companies are required to provide reports for the tax authority of the company’s country of residence. The countries participating in CARF have also agreed on reciprocated obligations to exchange these data automatically. The crypto-asset information exchange will take place between the countries of residence of the users. More than 70 countries and jurisdictions have joined the framework, as part of the CARF commitment process (https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/commitments-carf.pdf).

The statutory base in the European Union for joining CARF is the DAC8 directive (2023/2226/EU, amending the Directive on Administrative Cooperation). In 2027, the EU Member States will initiate an automatic exchange of information under the DAC8 Directive. The data to be exchanged will concern the 2026 calendar year. For non-EU states undertaking an exchange of information on similar crypto transactions, the statutory base is the Multilateral competent authorities agreement on the automatic exchange of information related to CARF, or alternatively, a bilateral agreement between the states concerned. To start an exchange of information between an EU Member State and a non-EU state requires that an exchange relationship has been activated. Finland applies the Multilateral competent authorities agreement (CARF MCAA) as of 1 January 2026 and will proceed to exchange information with the states that have activated an exchange relationship. The first exchanges of information, which will concern data for 2026, are scheduled for 2027. Some non-EU states have made commitments to initiate the automatic exchange of information later than in 2027.

Reporting crypto asset service providers (CASPs) in Finland need to send the Tax Administration their data in the form of an annual information return. The deadline for the return, which is specially designed for the purpose, will always be the end of January following the reportable calendar year. After the information returns arrive, the Tax Administration will create special data files that will be broken down country for country for sending to the tax authority of each country.  Examples of the content of the information to be exchanged include the sum totals, by every cryptocurrency, of the transactions that the taxpayer had made, facilitated by the reporting crypto asset provider, involving sales, purchases, exchanges, and transfers.  In general, the information exchange for every reportable year should be completed between EU Member States and non-EU countries by the end of September the following year.

3 Spontaneous exchange of information

The spontaneous exchange of information concerns specific tax cases and is often non-recurring. Information that is not included in the automatic exchange of information is sent spontaneously to another country. Information that is obtained through tax control and may potentially have an impact on taxes in the receiving country can be sent as spontaneous information to foreign tax authorities. Sending information for cross-referencing or purposes of comparison is important when there is a likelihood of a participating country losing tax revenues. The tax authorities of other countries that have an interest in this information should be informed of any action that points toward a systematic avoidance of taxes.

The objectives are to ensure that the tax treaty and national legal standards are correctly applied on the income received by an individual, and to prevent international tax evasion. Correspondingly, information sent to Finland is used to ensure that taxpayers’ tax is assessed correctly and at the correct amount.

The spontaneous exchange of information takes place based on income tax treaties, agreements on information exchange, and administrative assistance, and the Directive and Regulation on administrative cooperation. Information is exchanged between the competent authorities of EU Member States using a standard electronic form.

4 Exchange of information on request

Exchange of information on request refers to obtaining the necessary information through a co-operation setup between public authorities, in a situation where the information is located in a foreign country, typically in the records of a foreign bank. The tax authority of a foreign country would fulfil a request to collect certain information, applying the provisions of the legislation in force in the foreign country, and to send the collected information to the Tax Administration. Correspondingly, in accordance with Finnish legislation, the Tax Administration has committed itself to collecting and providing similar information requested by the competent authority of another country in accordance with internationally agreed standards.

Requests for administrative assistance may broadly concern practically any information or matter that is related to categories of tax, as defined by relevant tax treaties. The Directive on Administrative Cooperation in income tax matters, and Council regulation on value-added tax, have laid down deadlines for responding to administrative assistance requests.

The need to request administrative assistance may arise in any unit of the Tax Administration. Sending an administrative assistance request and responding to it, similarly to all administrative cooperation and exchange of information, takes place exclusively between competent authorities.

The legal base for requests for administrative assistance related to taxes consists of the convention on mutual administrative assistance, of the tax treaties on income tax in force, of agreements on administrative assistance, of the EU Directive on administrative assistance and the EU Regulation on administrative cooperation. In administrative assistance agreements, the term “administrative assistance” covers not only the exchange of information on request, but also administrative assistance given for the international recovery of taxes. In administrative assistance for tax recovery, the receiving country’s authorities can initiate collection measures to cover unpaid taxes expired in the sending country. Read more about international administrative assistance in the field of tax recovery in “Recovery of unpaid taxes through administrative assistance” — Kansainvälinen virka-apu verojen perinnässä (in Finnish and Swedish).

5 Publicity and confidentiality 

The Tax Administration is bound by a general confidentiality requirement (under the Act on the public disclosure and confidentiality of tax information (1999/1346)). Information obtained through the exchange of information in accordance with Article 22 of the Convention on Mutual Administrative Assistance in Tax Matters and Article 16 of the Directive on Administrative Cooperation is subject to the same confidentiality obligation as national tax information; however, so that the use of information is only limited to the purposes defined in the Convention and Directive. When data is being processed, the rules on data protection are followed.

In addition to national legal rules and norms, the Directive 2011/16/EU, the EU General Data Protection Regulation 2016/679/EU ('GDPR’), contains detailed rules on data protection. Further data protection rules are found in international agreements. The activities of information exchange are handled by or directed by tax officials appointed to these tasks at the Tax Administration, to ensure confidentiality, compliance with restrictions of use, and data protection. No information is exchanged without an appropriate legal basis.

Tax offices can also give public income tax information to external parties within the scope of the general service principle. For example, if a foreign company contacts a tax office to ask for information about an individual residing in Finland, some of which is public tax information and some is not, the tax office can give the requesting company an extract of public tax information.

More information about the publicity of tax information and the processing of data is available in the instruction Data security and the processing of personal data at the Tax Administration.

6 International exchange of information relative to the taxpayers’ obligation to report information 

According to section 7, subsection 1 of the Act on assessment procedure, taxpayers must declare their taxable earnings, any deductions, information about their assets and debts, as well as other relevant information to the tax authority for tax assessment purposes. The obligation to report information applies to income earned and generated in Finland and abroad, and to assets and property located in Finland and abroad.

As a rule, individual taxpayers and estates of deceased individuals receive a pre-completed tax return after the end of every tax year, and they are under an obligation to verify the amounts and other information which is pre-completed or pre-filled. In the event of errors and omissions, the individual taxpayers or estates will also have a duty to make corrections and to supplement the information and after that, send the return back to the Tax Administration. Another obligation that lies with the taxpayer is to voluntarily submit a tax return, even if they had not received a pre-completed tax return, if they received income subject to tax, had property and assets, or if they have other reportable information concerning the tax year that had ended.

If a taxpayer fails to send back their pre-completed tax return or make corrections to its information through e-services, they will be deemed to have submitted their return as it was, with the information and amounts that were pre-completed. This way, the taxpayer will be deemed to have declared their taxable income, assets, deductions and other relevant information as they were on the pre-completed tax return.

The international exchange of information does not eliminate the taxpayers’ obligation to report their foreign income and assets. For the most part, the Tax Administration will only receive information through information exchange at a point in time when pre-completed tax returns for the past tax year are sent out to Finnish taxpayers already. On the other hand, from the perspective of assessing a taxpayer’s taxes, the majority of the received information cannot be used as it is. Often, the received information will only serve the purpose of monitoring the way the Finnish taxpayers fulfil their obligations to report information and declare income, etc. From this, it follows, that the taxpayers themselves need to declare their foreign income themselves. However, as an exception to the above, information on pensions paid by Swedish payors to individuals residing in Finland is obtained so early after the tax year’s end that it can be used during the Tax Administration’s process of pre-filling the amounts for the individual taxpayers’ pre-completed tax returns. This reduces the need for taxpayers to supplement their tax returns in Finland. However, in these situations as well, taxpayers are under a duty to check the accuracy of the information. The information content and new developments relating to it are the subject of regularly ongoing negotiations between the participating countries. Nevertheless, there may be uncertainties in the transfer of information, for example, if a Finnish individual starts receiving a new type of pension from a payor in Sweden. In the same way, any changes to the way tax information is being collected in any of the participating countries are likely to increase the margin for error.

If, through information exchange, the Tax Administration receives information after the due date for submitting tax returns, and the individual taxpayer had not indicated that information on his or her tax return, the Tax Administration would always give the individual an opportunity to submit a written account in order to declare any undeclared income.

If the information arrives at a stage when the Tax Administration has already finished its assessment process for the tax year concerned, and no income tax was thus imposed on an income item, the Tax Administration can adjust the assessment afterwards to the individual taxpayer’s detriment, during the three years that follow the year after the tax year (section 56 of the Act on assessment procedure). The provisions of section 56b, subsection 1, paragraph 3 of the Act on assessment procedure – that came into force on 1 January 2017 – control an extension of the time limit for adjusting tax assessment in connection with received information other than automatically exchanged information, which is six years from the beginning of the year following the end of the tax year. Starting in 2026, the provisions of the section no longer contain the restriction to information received through methods other than automatic exchange. This means that the Tax Administration can use all the information to be received through international exchange of information for purposes of making adjustments to assessment of taxes within the scope of the six-year period.

In addition to a tax adjustment, a punitive tax increase can be imposed on a taxpayer due to income missing from a tax return (section 32 of the Act on assessment procedure). Neglecting the obligation to report information may also fulfil the criteria of a tax offence and lead to a criminal conviction.

More information on the obligation of individual taxpayers to provide information is available (in Finnish and Swedish) in the Tax Administration’s instructions ”Obligation of natural persons and death estates to report information for income taxation” — Luonnollisen henkilön ja kuolinpesän ilmoittamisvelvollisuus tuloverotuksessa.