Finland

Tax residency

Under Section 11 of the Finnish Income Tax Act (Tuloverolaki, TVL), an individual is a Finnish tax resident if their main abode and home are in Finland or if they stay in Finland for a continuous period of more than six months.

Thus, Finnish domestic tax residence may arise through main abode and home in Finland or through a continuous stay exceeding six months. The three-year rule is a separate post-departure rule for Finnish citizens.

• Main abode and home (asuinpaikka): this test concerns whether Finland is the individual’s longer-term place of residence and a centre of specific personal interests. The duration of the stay is relevant but is not, by itself, determinative. A stay of less than six months may qualify where the circumstances show that Finland has become the individual’s main abode and home.
• Six-month stay: a person whose main abode and home are abroad may nevertheless become a Finnish tax resident through a continuous stay in Finland exceeding six months.
• Three-year rule for Finnish citizens (kolmen vuoden sääntö): a Finnish citizen who moves abroad generally remains a Finnish tax resident for the calendar year of departure and the following three calendar years, unless they demonstrate that their substantial ties with Finland have been broken.

Day counting

• Main abode and home (asuinpaikka): no fixed day-count threshold applies. The assessment is based on the individual’s residential circumstances, including where they live and work and where their family lives.
• Six-month stay: the relevant period is measured as one continuous period of more than six months from the start of the stay and may cross calendar-year boundaries. The dates of arrival and departure are included in the calculation. Temporary absences do not necessarily interrupt the period. Finnish Tax Administration practice indicates that an absence of more than two months will generally interrupt continuity, although the assessment remains fact specific.
• Three-year rule (kolmen vuoden sääntö): this is a calendar-year rule rather than a day-count test.

Tax consequences

The Finnish tax year is a calendar year. Finnish tax residents are generally subject to tax on worldwide income, while non-residents are generally taxed only on Finnish-source income.

Migration / EU residence

EU/EEA and Swiss citizens may reside in Finland without a residence permit. If they intend to stay for more than three months, they must register their right of residence under the applicable rules. Third-country nationals may stay in Finland for up to 90 days in any 180-day period, subject to applicable visa requirements. Stays exceeding 90 days generally require a residence permit. Immigration residence status or registration does not, by itself, determine Finnish tax residency.

Orientation references

• Finnish Income Tax Act (Tuloverolaki, TVL), Section 11
• Finnish Tax Administration (Verohallinto / vero.fi), tax residency, six-month rule and three-year rule
• Finnish immigration / EU residence framework