Finnish Tax Administration: reclassification of certain occupational healthcare services as VAT-taxable supplies

Pursuant to this guidance, certain services that were previously treated as VAT-exempt healthcare supplies are now classified as taxable expert services subject to VAT.

Under the revised guidance, the following occupational health services are reclassified as VAT-taxable supplies with retroactive effect from 1 January 2024:

• Preparation and updating of an occupational health action plan

• Work ability support for client organisations

• Reporting to companies

• Contacts, advisory services and other coordination for companies

• Occupational safety activities

• Multidisciplinary collaboration meetings

• Preparation of Kela’s annual activity report

This reclassification does not affect the scope or content of services delivered directly to employees. The guidance is based on findings from a tax audit and has sector-wide application; it is not limited to Pihlajalinna. Pihlajalinna’s pricing will be updated to reflect the revised VAT treatment with effect from 1 May 2026.

As the guidance applies retroactively to tax periods from 1 January 2024, Pihlajalinna is required to account for and remit VAT on the affected organisational-level services for prior periods. Accordingly, clients will receive supplementary invoices covering the outstanding VAT for the relevant historical periods. The retroactive charge is limited strictly to the VAT amount due under the Tax Administration’s guidance. Any interest on late payment or other ancillary tax costs will be borne exclusively by Pihlajalinna.

For VAT-registered clients, VAT constitutes a neutral pass-through item. Clients will receive a supplementary invoice from Pihlajalinna for the VAT amount only. Provided the services relate to the client’s taxable business activities, the input VAT is fully recoverable by the client. As a result, the VAT charge should not represent a net cost to the client nor affect its profit or loss for the relevant period.

Clients will receive itemised invoices for each tax year separately, clearly identifying the organisational-level occupational health services to which the VAT charge relates.

Pihlajalinna intends to challenge the Tax Administration’s position by filing an appeal with the Tax Adjustment Board. In the event that subsequent rulings or decisions alter the applicable VAT treatment, Pihlajalinna will revise its approach accordingly and communicate any changes to clients.

Should you have any queries regarding the above, please do not hesitate to contact us. Enquiries may be directed by email to [email protected].