Finland: Updated FATCA guidance; new rules under cryptoasset reporting framework (CARF)
Recent tax developments under the FATCA regime, and new rules under the cryptoasset reporting framework
The KPMG member firm in Finland has prepared reports about the following tax developments under the FATCA regime, and new rules under the cryptoasset reporting framework (CARF).
The tax administration of Finland on September 15, 2025, issued an updated version (v3.4) of its FATCA technical guidance. The changes in the FATCA technical guidance include:
- Correcting Information (Section 5.1): Clarifies that when a reporting financial institution needs to remove previously reported individual account information, the ‘FATCA3’ (void data) code must be used in the reporting financial institution structure.
- Account Holder structures/Individual (Section 6.3.3.1): Updated to reflect two additional requirements outlined in the U.S. tax authority’s (IRS) Notice 2024-78.
- AddressFix (Section 6.4.2.1): Updated to incorporate the requirement related to the ‘AddressFix’ structure as outlined in IRS Notice 2024-78.
- DocSpec Structures (Section 6.4.3): Now mandates reporting of the business ID and tax year under the DocRefId element.
- List of Automated Checks Made by Ilmoitin (Section 7)
- List of Messages from Ilmoitin (Section 8): Clarifies that system-generated alerts related to AccountHolder/Individual/TIN, …/Individual/TIN, and …/Individual/BirthInfo/BirthDate will now trigger only when the TIN is issued by the United States.
Read the October 2025 report
The tax administration of Finland on September 25, 2025, published a newsletter announcing upcoming reporting obligations for cryptoasset service providers (CASPs). The new rules are based on the OECD’s cryptoasset reporting framework (CARF) and the EU’s DAC8 directive. Once the government proposal is passed by Parliament—expected by December 31, 2025—these obligations will be incorporated into Finland’s domestic legislation, becoming effective on January 1, 2026.
Key points of the proposed obligations for CASPs include:
- Starting in 2026, CASPs will be required to collect detailed information on both Finnish and non-Finnish crypto-asset users. The first annual reports, which will summarize the total transaction amounts for each cryptoasset, are expected to be submitted in January 2027.
- In addition to aligning with the EU’s DAC8 directive and OECD’s CARF, the government’s proposal introduces broader reporting obligations. CASPs must report sufficient information to enable the tax administration to calculate capital gains and losses on cryptoassets held by Finnish residents and estates.
Read the October 2025 report