Finland Aligns with EU: All Factoring Fees Taxable and ViDA Reforms Underway

Finland has clarified that all fees related to factoring services are subject to VAT, following a Supreme Administrative Court ruling aligned with EU case law. At the same time, draft legislation proposes implementing EU ViDA reforms, including changes to OSS and phasing out call-off stock rules from 2027. Overall, these developments reflect stricter VAT treatment and continued alignment with EU digital tax reforms

In its final ruling (SAC 2026:8), following an ECJ preliminary decision, the Supreme Administrative Court confirmed that all fees related to factoring services—including commissions, credit fees, and setup charges—constitute VAT-taxable consideration. This clarifies that factoring involving receivables collection is treated as a taxable service in full.

In parallel, draft legislation (VM163:00/2025) proposes amendments to the Finnish VAT Act to implement ViDA measures, including changes to the One Stop Shop (OSS) and the gradual phase-out of the call-off stock scheme, with entry into force planned for 1 January 2027. The proposal is currently open for consultation until March 31, 2026.

These developments reflect Finland’s alignment with EU VAT principles, combining stricter taxation of financial services with broader digital VAT reforms. While the factoring ruling increases tax costs for affected businesses, the ViDA implementation signals further system modernization and harmonization across the EU.