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Finland

Central Tax Board clarifies VAT treatment of e-commerce payment services

3 days ago
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Finland — Central Tax Board clarifies VAT treatment of e-commerce payment services (KVL:013/2026)
Summary
  • KVL:013/2026 (“Central Tax Board Preliminary Decision”) clarifies VAT on payment services provided to online retailers. A single “payment solution” bundle can contain taxable and VAT-exempt components; each service must be assessed separately on its VAT nature, not the overall package. [globalvatc…liance.com]
  • The ruling addresses a provider integrating its solution into merchant e-commerce platforms and enabling payment through both its own methods and third-party providers’ methods. Fees for own methods = taxable factoring; API technical connectivity to third-party providers = taxable; payment processing/fund transfer from external PSPs to merchants = VAT-exempt payment transaction. [globalvatc…liance.com]
  • The preliminary ruling applies from 28 April 2026 through 31 December 2027. E-commerce platforms and payment providers should re-examine invoicing/VAT coding for bundled offerings and, where applicable, apportion or split the components to reflect the correct VAT treatment. [globalvatc…liance.com]
Article
The Finnish Tax Administration has published Central Tax Board Preliminary Decision KVL:013/2026, providing much-needed clarity on the VAT treatment of the increasingly common bundled payment service offerings that payment service providers (PSPs) sell to online retailers. [globalvatc…liance.com]
The facts concerned a PSP that integrated its payment solution into merchants’ e-commerce platforms, allowing end-customers to pay either through the PSP’s own payment methods or through third-party payment methods. The Central Tax Board split the offering into three distinct services with three different VAT outcomes:
  • Service fees relating to the PSP’s own payment methods → taxable factoring services supplied to the online retailer;
  • Technical / API services connecting third-party payment providers to the merchant’s platform → subject to VAT;
  • Processing customer payments received from external payment service providers and transferring the funds to the merchant → qualifies as a VAT-exempt payment transaction. [globalvatc…liance.com]
The key legal message is that a single commercial “payment solution” may contain both taxable and VAT-exempt elements, and each service must be assessed separately on its individual VAT nature — the overall label of the offering does not determine the VAT treatment. [globalvatc…liance.com]
The preliminary ruling applies from 28 April 2026 to 31 December 2027. For e-commerce operators and PSPs with Finnish exposure, this is a prompt to:
  1. Map bundled payment offerings into constituent services;
  2. Apportion or invoice separately the taxable (factoring, API/technical) and exempt (payment transaction) elements;
  3. Update input VAT recovery models — VAT on inputs allocable to VAT-exempt payment transactions is generally not recoverable;
  4. Reflect the analysis in customer contracts and price lists.
The wider Finnish VAT context is available in the VATupdate Finland 2026 Country Guide — including the standard rate of 25.5%, the new 13.5% reduced rate from 1 January 2026, and the €20,000 registration threshold.
Sources

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