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FinlandVero

KVL: drill guides for dentists VAT-free under AVL 36(5)

KVL:022/2026: custom implant drill guides sold to dentists are VAT-free under AVL 36(5) when made by registered dental technicians for an individual patient and used immediately in exempt care.

By Taxxa AI OyPublished 5 October 2026

Tax

A company manufacturing and selling implant drill guides for dentists' use does not charge VAT on the guides when all conditions of Section 36(5) of the VAT Act are met.Vero The Central Tax Board (KVL) advance ruling KVL:022/2026, published 5 October 2026, applies to 21 August 2026Vero through 31 December 2027Vero and is not yet finalVero.

A Oy manufactured and sold drill guides used by a dentist when fitting an implant into a patient's jawbone. It could sell dentists the guide alone or the guide together with the implant. A dental technician employed by A Oy designed the guide in CAD software from combined patient data supplied by the dentist, while the milling itself was bought from B Oy. The technicians were entered in the central register of healthcare professionals (JulkiTerhikki)Vero, and the licensing authority had authorised the company's employees to practise as licensed professionals.

The sale of the guide was treated as a sale independent of and separate from the sale of the implant. The guide was a dental-technical device, not a dental prosthesis within the meaning of Section 36(3) of the VAT ActVero (hammasproteesit sold by a dentist, dental technician or specialised dental technician), so the sale was not VAT-free on that basis.

Exemption followed instead from Section 36(5)Vero: goods and services for immediate use in healthcare, supplied in that activity by a private healthcare provider or a registered healthcare professional to another such provider or professionalFinlex. Applying KHO 2013:40, the supplier condition was met: since the principal shareholder's registration as an independent practitioner sufficed regardless of whether the company held a private-healthcare licenceVero, A Oy's employees could be equated with the principal shareholderVero. The manufacture and sale of the guide for an individual patient's needs took place in that activityVero, and the guides were used immediately in the recipient's VAT-exempt healthcare servicesVero. With every condition of Section 36(5) fulfilledVero, the company charged no VAT on sales of the guides to dentistsVero.

The legal basis is the VAT Act (arvonlisäverolaki 1501/1993), Sections 1(1)(1), 34(1), 35, 36(3), 36(5) and 190a.

If you supply custom dental-technical devices to VAT-exempt healthcare providers, check every AVL 36(5) condition (registered supplier, individual-patient need, immediate use in exempt care) and note KVL:022/2026 is not yet final before treating sales as VAT-free.

Sources

FinlandVero

KVL: drill guides for dentists VAT-free under AVL 36(5)

KVL:022/2026: custom implant drill guides sold to dentists are VAT-free under AVL 36(5) when made by registered dental technicians for an individual patient and used immediately in exempt care.

By Taxxa AI OyPublished 5 October 2026

Tax

The legal basis is the VAT Act (arvonlisäverolaki 1501/1993), Sections 1(1)(1), 34(1), 35, 36(3), 36(5) and 190a.