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FinlandVero

KVL: pawnshop auction fees carry VAT, not credit exemption

Pawnshop auction fees billed to borrowers are VAT-able collateral-sale services, not exempt credit, under CJEU C-89/23; ruling valid 21 Aug 2026–31 Dec 2027, not final.

By Taxxa AI OyPublished 2 October 2026

Tax

A pawnshop that sells unredeemed pledges at auction must charge VAT on the auction-related fees it bills the borrower, the Central Tax Board (KVL) holds in advance ruling KVL:023/2026.Vero The fees are consideration for a VAT-able service of selling the pledged itemVero, not consideration for the exempt granting of creditVero — even though they are charged in connection with a loan.

The ruling concerned A Oy, a panttilainaamo lending against movable property. When a borrower neither redeemed the pledge nor renewed the loan by the due date, the loan fell due and A Oy sold the pledge at a panttihuutokauppa auction. At the point of transferring the item for auction sale, A Oy charged the borrowing customer four fees: a pawn-auction fee (panttihuutokauppamaksu), a transfer-to-auction-system fee (huutokauppajärjestelmään siirtomaksu), a surplus-notification fee (ylijäämän ilmoitusmaksu) and a fee connected with the early sale of the collateral (vakuuden ennenaikaiseen myyntiin liittyvä maksu).Vero

KVL follows the Court of Justice judgment in C-89/23, Companhia União de Crédito PopularVero: services connected with organising auction sales of pledged goods are not ancillary to the principal supply of granting pledge-secured credit within the meaning of Article 135(1)(b) of the VAT DirectiveEuropa, so they do not share the credit's VAT exemptionEuropa. Applied to A Oy, the four fees cannot be treated as consideration for the credit serviceVero; they are consideration for the service of selling the item held as security for the pawn loanVero, supplied to the borrowing customer. That is a taxable supply of servicesVero, so A Oy must account for VAT on each of the four feesVero.

The ruling cites Arvonlisäverolaki 1 §(1)(1) (scope of VAT), 18 §(2), 41 § (no VAT on the sale of financial services), 42 §(1)(2) (lending and other financing arrangements as financial services) and 190 a §, together with C-89/23 and C-94/19 (San Domenico Vetraria). The statutory frame matters: lending itself stays an exempt financial service under 41–42 §Finlex, but the auction-sale service falls outside itVero.

The advance ruling covers the period 21 August 2026 to 31 December 2027Vero and is not yet final (ei lainvoimainen)Vero. Pawnshops and other lenders charging borrowers for the sale of pledged collateral should treat such fees as VAT-able unless and until a final decision says otherwise, and advisers should distinguish the credit from the collateral-sale service in fee structures.

Legal basis: KVL:023/2026, applying Arvonlisäverolaki 41 § and 42 §(1)(2) with EUT C-89/23, Companhia União de Crédito Popular SA.

If you run a pawnshop or lend against pledges, charge VAT on auction and collateral-sale fees billed to borrowers, and keep the credit service separate from the sale service in your fee structure.

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