Submitting an appeal — transfer taxation
This guidance concerns individual and corporate taxpayers alike. It only concerns decisions issued by the Tax Administration after 1 January 2017.
You can appeal against a decision made by the Tax Administration concerning transfer tax. These include the following types of decisions: a decision to impose transfer tax, and a decision that was made in response to a request for refund.
In the case of a preliminary ruling on transfer taxes, the rules on how to make an appeal are different. Read more about how to appeal against preliminary rulings (the guidance is available in Finnish and Swedish).
Make a claim for adjustment in MyTax
You can file a claim for adjustment electronically in MyTax. MyTax displays the Tax Administration’s decisions, dated on 8 November 2019 or later. You can also make a claim for adjustment in MyTax for a decision on transfer taxation issued before that, provided that its appeal period has not ended yet.
You can still send us your claim on paper if necessary. File the claim of adjustment on Form 6018e ‒ Claim for adjustment of transfer tax. Alternatively, you can write out the claim in your own words.
The following information is always required:
- Appellant's name and personal identity code/Business ID
- The decision you are seeking to change (give the decision number)
- An explanation of how you want it to be changed
- The reasons why you ask for the changes
- Enclose photocopies of any relevant documents that support your claim, unless you have sent them to the Tax Administration previously. If you have an agent handling your taxes and you wish to have the decision letter sent to him or her, please indicate this on your claim and give the agent's address as appropriate.
If you use the paper form to file your claim, send the completed form and enclosures to the address on the first page. Alternatively, deliver it to any tax office.
What is the deadline for the claim for adjustment?
The deadline is 3 years from the end of the tax year, but no less than 60 days from the date when the taxpayer was first informed of the decision on transfer taxation.
For purposes of the above rule, “tax year” means the calendar year when the real estate, asset, property, share, etc. was transferred, or when the liability to pay transfer tax had arisen due to some other reason.
Example: The date when Janne bought his house was 1 February 2020. He accidentally paid too much transfer tax on it. He asks for refund of the excess amount paid, and receives a decision on this request on 1 June 2020. He has until 2 January 2024 to appeal against the decision (noting the fact that 31 Dec 2023 will fall on a Saturday, so he can still send his appeal on the next business day).
In other words, Janne would have had until 2 January 2024 to make a request for a refund. However, if Janne did make his request only by 2 January 2024 and would then receive the decision only in 2024, the appeal period would be 60 days after he receives the decision.
Only claims submitted within the appeal period will be considered
Claims of adjustment must be delivered to the Tax Administration before the appeal period is over. Documents must be sent off by post in time to arrive to the Tax Administration no later than on the last day of the appeal period by 4:15 pm. Note: if you submit your claim in MyTax, you must do so by 4:15 pm on the last day, as well. Claims that arrive late will not be considered.
Tax must be paid even if an appeal is pending
Although an appeal has been filed, transfer tax must still be paid on their original due dates. However, if an appeal is pending, the appellant may petition the Tax Administration to issue an order preventing or postponing the recovery action against the taxpayer. Read more about interruption of enforced recovery. Regardless of any such order, the original transfer tax continues to be in force. As a result, late-payment interest and other penalty charges may be added to it.
Appeals to the administrative court and Supreme Administrative Court
If you disagree with the Adjustment Board's decision and want to make a further appeal, you must submit that appeal to an administrative court. The appeal period is 60 days from the date when you received notice of the decision on your original appeal. Appeals must arrive to the administrative court no later than 4:15 pm on the appeal period’s last day.
The administrative court where you should send your appeal is the one that has jurisdiction over the region of Finland where the real estate is located if the Adjustment Board’s decision concerned a real estate unit, and correspondingly, the court that has jurisdiction over the region of the company’s domicile, if the Adjustment Board’s decision concerned corporate securities that a company had issued. If the decision concerned both real estate and securities, appeals must be submitted to the administrative court that has jurisdiction at the real estate’s location. If these grounds cannot be applied, the appeal must be submitted to the Helsinki Administrative Court.
Check the addresses of administrative courts (www.oikeus.fi).
Alternatively, you can send the appeal via the e-Service of the Administrative and Special Courts (in Finnish and Swedish only). Even in the case of an appeal made through the e-service, the appeal must arrive at the administrative court by 4:15 pm on the appeal period’s last day.
A ruling by the administrative court is open to appeal in the Supreme Administrative Court, if the Court grants leave for this. You must make the appeal within 60 days of receiving notice of the administrative court’s decision.
Appeals to an administrative court or to the Supreme Administrative Court may be subject to a fee.
More information on the fees charged by courts of law (www.oikeus.fi).