Finland: Updated guidance on negligence fees for third-party declarants

Updated guidance relating to obligations under Sections 14f and 17a–f of the Tax Procedure Act, which include requirements under FATCA and CRS

The Finnish Tax Administration on October 16, 2025, published updated guidance on negligence penalties for third-party declarants, relating to the obligations under Sections 14f and 17a–f of the Tax Procedure Act (VML), which include requirements under FATCA and the common reporting standard (CRS).

The key updates to the guidance are as follows:

Section 6.1 (General information): This section has been updated to clarify that penalties will increase if the same non-compliance occurs in consecutive reporting periods. The increase applies when previously imposed penalties have not led to corrective actions by the reporting entity.
Section 6.2.1 (Imposing penalties for failure to comply with due diligence obligations): This newly added section states that penalties for failure to comply with due diligence obligations are determined on a case-by-case basis, typically following inspections. These penalties are assessed based on factors such as the volume of data involved. Failure by reporting entities under FATCA and CRS to carry out proper due diligence procedures may create significant challenges for the Tax Administration in verifying the accuracy of reported data. The period for assessing non-compliance with due diligence obligations aligns with the reporting period used for reporting obligations.

Read a November 2025 report prepared by the KPMG member firm in Finland

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Finland: Updated guidance on negligence fees for third-party declarants

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