Finland's Tax Administration has tightened rules on late tax filing, imposing fixed fees of EUR 50–100. New guidance clarifies when penalties are waived—for technical failures, minor oversights, or circumstances beyond taxpayer control. Stricter tax increases apply to errors discovered by authorities or left uncorrected after the assessment period. A recent Supreme Court decision has refined when reduced penalties apply.
Finland’s Tax Administration has released updated Guidance No. VH/2608/00.01.00/2026 on 21 May 2026, which outlines the updated regulatory framework for income tax penalties in Finland, focusing on the distinction between late fees and tax increases.
The revisions clarify that penalties may apply to tax returns or corrections submitted after the deadline but still within the assessment period for the tax year. They also confirm that late filing fees will not be imposed where delays are due to factors beyond the taxpayer’s control, minor omissions, or other valid reasons as defined.
In addition, the guidance restates tax increase rates at 2% of additional income and 10% of increased tax. It also reflects Supreme Administrative Court Decision KHO:2026:4, which reduced the applicable rate to 1% in certain circumstances.
Regarding the imposition of late filing penalties and tax increases based on the provided guide, here is a detailed breakdown of the relevant procedures and exceptions:
Imposition of late filing penalties (late fees)
A late fee is imposed instead of a tax increase if a taxpayer files a return or voluntarily corrects a reporting failure after the deadline but before the end of the taxation period for that specific tax year.
For natural persons and estates, the fee is EUR 50 per tax year. For other taxpayers, such as limited liability companies or partnerships, the fee is EUR 100 per tax year.
Income taxation ends on an individual basis as stated in the taxpayer’s taxation decision. For communities, it ends no later than 10 months after the tax year; for others, no later than the end of October the following year.
Only one late fee is imposed per tax year for all eligible omissions. However, if a return is filed only after the taxation period has ended, a more punitive tax increase is applied instead.
Non-application of late filing fees
- Reasons beyond control: The Tax Administration will not impose a late fee if the delay is due to reasons beyond the taxpayer’s control, if the negligence is minor, or if there is a valid or special reason. This includes technical malfunctions in public information networks or the Tax Administration’s electronic services.
- Minor negligence: Defined by two measures—either the added income does not exceed EUR 2,000 or the additional tax owed is EUR 500 or less. Alternatively, returns filed within three days after the deadline are considered minor oversights. However, repeated or deliberately negligent behaviour disqualifies this exemption.
- Valid reasons: Sudden illness or force majeure circumstances warrant exemption. Notably, vacation time or workload pressures do not qualify.
- Special reasons: Accidental calculation or data entry errors, or corrections made immediately following a company’s annual general meeting, are treated as special circumstances.
Tax increase rates
A tax increase is imposed when returns are submitted incorrectly, incompletely, or not filed at all, provided the taxpayer has not voluntarily corrected the error before the end of the taxation period. The amount of the increase is calculated according to percentage base levels established in Sections 32a and 32b of the Act on Tax Procedure (VML), which determine the specific penalty rates applied to undeclared income and additional tax liability.
Supreme Administrative Court decision (KHO:2026:4)
The Supreme Administrative Court’s Decision No. KHO:2026:4 prompted the Tax Administration to update its official instructions, with notable changes introduced in section 3.2.7 on reduced tax increases. While the ruling’s existence and its influence on the guidelines are documented, the specific penalty reductions it mandated are not detailed in the available sources. What is confirmed is that the decision refined the criteria governing when reduced tax increases apply under particular circumstances, thereby enhancing the precision and fairness of penalty administration.
Distinction between tax returns and supplementary forms
The imposition of a late fee depends on what specific type of information is filed late.
- Tax returns: Late fees apply to the late filing of “main” tax forms, such as those for communities (6B), business associations (6A), agricultural activities (2), or business and professional activities (5).
- Supplementary forms: Forms providing more detailed breakdowns (e.g., depreciation, rental income [7H], or capital gains) are not considered tax returns for the EUR 50/100 late filing fee.
- Pre-filled returns: For natural persons, pre-filled information is deemed submitted on the due date. A late fee is only imposed if they fail to report additions or corrections (like business or agricultural income) by the deadline.
Interaction between late fees and tax increases
A taxpayer can be hit with both penalties for the same tax year. If a tax return is filed late (triggering a late fee) but also contains errors or omissions that are not corrected voluntarily, a tax increase is imposed on the added income in addition to the late fee.
Partnerships and third-party responsibility
- Partnership liability: While a partnership is not a separate taxpayer, late fees for a partnership’s reporting failures are imposed on the general partners in proportion to their shares.
- Agent errors: The taxpayer remains legally responsible for deadlines even if they have outsourced their filing to an accounting firm or trustee. A late fee will not be waived because of an error by a third party.
Handling of Deductions
Generally, no late fee is imposed if a taxpayer simply reports deductions or information beneficial to them late. A late fee may be imposed if a taxpayer repeatedly reports deductions late or shows “obvious disregard” for obligations, such as claiming the same deduction late every year without a valid reason.
