VAT representative in Finland: when a non-EU business needs one

Karma Accounts · Published 23 October 2026

A business with no place of business or fixed establishment in the EU or Norway needs a VAT representative in Finland when it applies to register for Finnish VAT voluntarily under section 12(2) of the VAT Act, on sales where the Finnish business buyer would otherwise pay the VAT under reverse charge. The representative must have its place of business in Finland and be approved by the Finnish Tax Administration (Verohallinto), which may also ask for a guarantee. A non-EU business that has to register, for example because it makes taxable sales to consumers in Finland, does not need a representative.

The rule is in section 173 a of the VAT Act. Precisely, it applies when the business has no place of business or fixed establishment in another EU country or in a country with a mutual-assistance arrangement with Finland equivalent in scope to the EU's rules on tax recovery and VAT cooperation. The Tax Administration's guidance names Norway as such a country. The Tax Administration has also confirmed that a UK company that registers voluntarily does need a representative.

Do I need a fiscal representative in Finland?

It depends on why you register, not only on where you are based:

Your situation	Finnish VAT registration	Representative
Sales in Finland to VAT-registered businesses, no fixed establishment here	Not needed: the buyer pays the VAT	No
Same sales, but you opt to charge Finnish VAT (section 12(2))	Voluntary	Yes, if no establishment in the EU or Norway
Taxable sales to consumers in Finland	Mandatory, unless an OSS scheme covers them	No
Sales in Finland to a foreign business with neither a Finnish fixed establishment nor Finnish VAT registration	Mandatory	No
Passenger transport or admission to events in Finland	Mandatory	No
A fixed establishment in Finland that participates in the sale	Mandatory	No
Eligible services to consumers in EU countries	Optional non-Union OSS scheme instead	No
Imported goods to EU consumers in consignments of at most 150 euros, excise goods excluded (IOSS)	Optional import scheme	An EU intermediary, in most cases

A non-EU business cannot use the Finnish 20 000 euro small-business limit: the VAT Act says the limit does not apply to a foreigner whose place of business is outside the EU. If you have taxable sales in Finland that reverse charge does not cover, you register from the first euro. The step-by-step process is in our guide to Finnish VAT registration for a foreign company.

When business-to-business sales use reverse charge

When a foreign business with no fixed establishment in Finland that takes part in the sale, and that has not opted into VAT liability under section 12(2), sells goods or services in Finland to a Finnish business, the buyer is liable for the VAT. This is reverse charge (käännetty verovelvollisuus): you invoice without Finnish VAT, add a note such as "reverse charge", and the buyer reports the VAT on its own return. You can read how reverse charge works for the Finnish buyer in our separate article.

Reverse charge does not cover sales to consumers, sales to foreign businesses with neither a Finnish fixed establishment nor Finnish VAT registration, passenger transport, admission to events in Finland, or distance sales of goods from another EU country. Where such taxable sales take place in Finland, registration is mandatory (ilmoittautuminen), unless a special scheme such as the OSS covers them. Mandatory registration requires no representative.

A foreign business may instead choose to register on application under section 12(2) of the VAT Act, so that it charges Finnish VAT to Finnish business customers like a local supplier and deducts the Finnish VAT on its purchases on its returns. After that it can no longer claim the separate VAT refund for foreign businesses. Only this voluntary route triggers the representative requirement for a non-EU business.

What a VAT representative does in Finland

The representative answers for the administrative obligations that come with the foreign business's VAT registration. In practice:

Records kept in Finland. The representative maintains the required bookkeeping, or notes if the foreign business is not obliged to keep books, that show reliably everything that affects the VAT, and keeps the material and invoices in Finland for the required period.
Filing. Under the Act on assessment procedure for self-assessed taxes, the representative is also responsible for filing the foreign business's VAT reports.
Tax audits. When the Tax Administration asks, the representative presents the principal's bookkeeping for inspection.
The bookkeeping itself. Approval normally requires the representative to do the bookkeeping and similar tasks itself.

The representative does not pay your tax: the Tax Administration's guidance states that it is not responsible for paying the tax imposed on the foreign business. The VAT remains your debt, which the Tax Administration can secure with a guarantee.

Approval and the guarantee

The Tax Administration has to accept the representative. According to its guidance:

the representative's place of business must be in Finland
it needs sufficient skill and expertise for the task
it should normally be entered in the Finnish Trade Register
a private individual is accepted only in exceptional cases.

The Tax Administration may also require a guarantee for payment of the tax, usually a bank guarantee. The amount is decided case by case; the law sets no figure.

To change representative, you notify the Tax Administration in advance and send the same documents for the new one, which must also be approved. If a representative gives up the role and you do not appoint an approved replacement after a reminder, the Tax Administration may treat your VAT registration as ended.

How the representative is appointed

The representative is named in the registration itself. A foreign company files a start-up notification on Form Y1 (Y2 for partnership-type businesses, Y3 for self-employed individuals) with appendix Form 6204 or 6206, available at ytj.fi, together with:

an extract from the home-country trade register showing the name, domicile, line of business, financial period and who may sign for the company
the articles of association or equivalent, if the extract does not cover them
a power of attorney, if someone other than an authorised signatory signs the notification
a commitment from the Finnish representative to act as the representative under section 173 a, where the foreign business itself signs the notification
a power of attorney from the foreign business to the representative, with a Finnish or Swedish translation
the representative's name, Finnish Business ID and contact details, plus evidence of competence if its line of business is not accounting.

Foreign-language documents need a Finnish, Swedish or English translation; the powers of attorney need Finnish or Swedish. The Tax Administration estimates that registration takes about three weeks on average; that is a forecast, not a deadline.

Filing returns in MyTax

VAT returns can be filed in MyTax (OmaVero) or other supported electronic channels. An outside agent who files for you needs the right Suomi.fi authorisation from the company: "Managing of tax affairs" gives access to MyTax, while "Filing of tax returns and other reports" only allows returns sent as files from accounting software through Ilmoitin.fi. When the people who sign for a foreign company have no Finnish personal identity code, the company grants the authorisation with an application on Suomi.fi, which Suomi.fi estimates takes about seven working days to process. Deadlines and the return itself are covered in Finnish VAT returns for a foreign company.

VAT representative, fiscal representative and accountant

VAT representative (Finland). The section 173 a representative described above: required only for voluntary registration by a business with no establishment in the EU or Norway, approved by the Tax Administration, responsible for records and filing, not for payment.

Fiscal representative (elsewhere in the EU). The EU VAT Directive allows member states to let a non-established business appoint a tax representative who is itself the person liable to pay the VAT, and to hold a person other than the taxpayer jointly and severally liable. Where a country uses those options, its fiscal representative carries part of the tax risk. Finland's representative is defined differently, so when a provider offers "fiscal representation in Finland", ask which role it means.

Accountant or authorised agent. Any business registered for VAT in Finland, including one that registered because it had to, can have an accounting firm keep its books and file its returns under a Suomi.fi authorisation. That needs no approval from the Tax Administration. An approved representative is needed only in the voluntary case.

A business with no EU establishment may opt for the non-Union OSS scheme for eligible services to consumers in EU countries, and report them in one EU country instead of registering in each. The scheme is optional, but once chosen it covers all the sales within its scope; it does not cover other transactions. See the OSS schemes for e-commerce VAT. For the wider picture, see the VAT guide for Finland.

What we do

Karma Accounts handles Finnish VAT registration and VAT returns for foreign businesses, in English. We check whether you need to register at all, prepare the start-up notification and its appendix, keep the Finnish VAT records and file the returns in MyTax under your Suomi.fi authorisation. Karma Accounts is not an approved VAT representative under section 173 a. If your business has no establishment in the EU or Norway and its voluntary registration needs one, the representative has to be a business the Tax Administration approves; we can still handle the returns and records alongside it. Ask through the quote request form. Finnish anti-money-laundering law covers accounting firms, so before we start we identify the company, the people acting for it and its beneficial owners.

Frequently asked questions

Do I need a fiscal representative in Finland?

Only if your business has no place of business or fixed establishment in the EU or in a country with an equivalent mutual-assistance arrangement (the guidance names Norway), and you apply to register for Finnish VAT voluntarily under section 12(2), on sales where your Finnish business customers would otherwise pay the VAT under reverse charge. If you must register, for example because you make taxable sales to consumers in Finland, no representative is required.

Is a VAT representative in Finland liable for the VAT?

No. The Tax Administration's guidance says the representative is not responsible for paying the tax imposed on the foreign business. The representative answers for the records and the filing; the Tax Administration can require a guarantee, usually a bank guarantee, to secure payment.

Can a non-EU company register for VAT in Finland without a representative?

Yes, when the registration is mandatory: taxable sales in Finland to consumers or to foreign businesses with neither a Finnish fixed establishment nor Finnish VAT registration, passenger transport, event admission, or a Finnish fixed establishment that participates in the sale. An accountant can then file the returns under a Suomi.fi authorisation without Tax Administration approval.

Does a UK company need a VAT representative in Finland?

If it registers voluntarily, yes. The Tax Administration changed its interpretation on 19 May 2021 and now says a British company registering voluntarily must name a representative under section 173 a.

Sources

Please note: this is general information about Finnish rules, not advice for your own situation, and the rules change. Ask us before you act on it.

Finnish VAT for a foreign company?

We register foreign companies for VAT in Finland and file their VAT returns and EC Sales Lists, quoted per scope. See Finnish VAT services for foreign companies. For VAT firms and accounting firms: working with us as a Finnish VAT partner.

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