7.2.2020

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.

Latest references

We acted as legal adviser to Banyan Software on its acquisition of Carus Ferry, a Finland-based provider of reservation, check-in and port operations software for ferry and passenger shipping operators. The acquisition further strengthens Banyan Software’s presence in the Nordic region while providing Carus with a long-term partner to support its continued growth and development. Carus was founded in 1998 and is headquartered in Mariehamn on the Åland Islands, Finland. The company develops mission-critical software for ferry, cruise and passenger shipping operators, covering the full passenger journey from booking and ticketing to capacity management, check-in and boarding. Carus also provides port automation, onboard sales systems and business information tools. The company serves approximately 30 operators across four continents and is the largest vendor by customer count in ferry reservation and departure control. Banyan Software is an acquirer and long-term operator of mission-critical software businesses serving specialised industries. Founded in 2016, Banyan follows a buy-and-hold-for-life approach and supports the long-term growth and development of its portfolio companies. Banyan operates more than 130 portfolio companies across North and South America, the United Kingdom, Europe and APAC. Following the acquisition of Carus, Banyan operates three businesses in the Nordic region.
Case published 20.10.2026
We advised Move Energy as an investor in connection with the combination of 3North Partners Plc and Steady Energy Oy and the related private placement and initial public offering of the combined company on Nasdaq First North Growth Market Finland. In connection with the transaction, 3North Partners received approximately EUR 69.8 million in investor commitments from a group of institutional and other investors, including Move Energy, to fund the combined company. Steady Energy is a Finnish nuclear technology company developing a new generation of small modular reactors (SMRs) particularly suited for district heating. Its LDR-50 reactor is designed to provide cities and utilities with a scalable and low-carbon alternative to combustion-based heat production.
Case published 19.10.2026
We advised Efima Oyj on the sale of its AI business to Better Care Technologies Oy. The transaction included Efima’s Moiva AI platform developed for the care sector, the related technology and brand, customer contracts, and the experts working in the business. Efima is a Finnish digital company that supports the sustainable growth of large and mid-sized companies by streamlining their business processes and by creating competitive advantage through the innovative use of artificial intelligence and data. The company has nearly 200 experts based in Helsinki and Tampere. 
Case published 21.9.2026
We advised Neoen Renewables Finland Oy, part of the French Neoen Group, in its sale of a data centre project to a consortium consisting of international data centre developers and operators. This marked Neoen’s first data centre development project in Finland. Founded in 2008, Neoen is one of the world’s leading independent renewable energy producers. The company operates in 15 countries. It develops, finances, builds, owns, and operates solar power plants, wind farms, and battery storage systems. Neoen Group is owned by global alternative asset manager Brookfield Corporation.
Case published 17.9.2026