07/02/2020

New Act on Reporting Obligation for Transactions

Finnish Parliament recently enacted a new act regarding reportable transactions in the field of taxation (in Finnish ‘Laki raportoitavista järjestelyistä verotuksen alalla’). The purpose of the act is to implement the European Union Directive on the mandatory disclosure and exchange of cross-border tax arrangements, generally referred to as DAC6.

The act requires intermediaries or taxpayers to report qualifying cross-border arrangements to local tax authorities. The reporting obligation applies only to specific types of transactions that are deemed to involve a risk of tax avoidance or tax abuse. The Finnish act includes certain exceptions governing attorneys-at-law.

Reportable arrangements generally include arrangements that were initiated as of 25 June 2018, i.e. the reporting obligation will be retroactive. The reporting obligation for transactions initiated between 25 June 2018 and 30 June 2020 needs to be fulfilled by end of August 2020.

The Finnish Tax Administration is expected to provide written guidance regarding the actual application of the act during the spring of 2020.

Our tax advisors will be happy to provide further details concerning the reporting obligation.