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Apply for a mutual agreement procedure
You can request a mutual agreement procedure (MAP) if you have been taxed contrary to a relevant tax treaty.
You can submit a MAP application to a tax treaty procedure or to an EU dispute resolution procedure.
You can apply for a tax treaty procedure if Finland has a valid tax treaty with the country involved in the matter.
Check the tax treaty to see what country the application must be submitted to. The application can usually be submitted to any/either of the countries involved in the mutual agreement procedure. According to some tax treaties, however, the application must be submitted to the country of residence. Your country of residence is the country where you lived in the tax year that the application concerns.
Check the time limit for submitting the application in the tax treaty. The time limit is usually three years from when you learnt for the first time that you had been taxed contrary to the tax treaty (for example, you received a tax decision).
You can apply for an EU dispute resolution procedure if the country involved in the matter is a EU Member State and if Finland has a valid tax treaty with it. Submit the application with the same content and at the same time to all countries that the mutual agreement procedure concerns. However, it is enough that you submit the application to the Finnish Tax Administration if you lived in Finland in the year that the application relates to.
The time limit is three years from when you learnt for the first time about your double taxation (for example, you received a tax decision).
How to make a MAP application
You can write a free-form application in Finnish, Swedish or English. There is no template form. If necessary, the Tax Administration will have your application translated into English and deliver it to the competent tax authority of the other country.
Use the heading “Application for a mutual agreement procedure”.
Provide the following information in the application:
- which procedure you apply for: a tax treaty procedure or an EU dispute resolution procedure
- what countries the matter concerns. State whether you have also submitted the application to the other country.
- your contact information: personal ID, foreign TIN or foreign personal ID (if any), address, telephone number, email address. If you use a representative, also provide their name and address for correspondence.
- tax years that the matter concerns
- how your taxes have been assessed in the other country and in Finland:
- what income has been taxed in both countries
- how much tax you have paid in the countries in question
- how and when you learnt about the double taxation (e.g. tax decisions you received)
- what decisions you have received on the matter
- attach copies of the decisions
- tax treaty articles and legislation that the countries’ authorities have applied in your tax assessment, if known to you
- state whether you have requested adjustment of or changes to your tax assessment in either country. If yes, attach copies of your applications and the decisions you have received, including a copy of the final decision on the amount of tax.
Also include the following in your application:
- a commitment to respond to information requests as quickly and thoroughly as possible and to provide the requested documents
- a declaration stating that you will keep confidential any information obtained in connection with the mutual agreement procedure with the exception of obligations arising from other legislation. If you have a representative, they must submit the same declaration.
Go to https://turvaviesti.vero.fi/ and send the application by email
to the Tax Administration mailbox MAP@vero.fi. Alternatively, you can send the application by post to:
Finnish Tax Administration/International matters MAP
P.O. Box 1
FI-00052 VERO
The Tax Administration provides advice and guidance on how to select the right procedure and make the application.
If necessary, call our service number (International income taxation of individuals).
If further information is needed, you will be contacted by the Finnish Tax Administration or the other country’s competent tax authority. Respond to information requests within the time limits given. The application can be rejected if it has been filed late or if it is materially incomplete.
Read more about taxation contrary to a tax treaty in other countries
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