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FinlandVero

Pawnbrokers must charge VAT on default-auction fees, CSN:023/2026 holds

Pawn-auction fees charged on defaulted pledges are consideration for the taxable sale service, not the exempt credit, so a pawnbroker must charge VAT on all four fees under CSN:023/2026.

By Taxxa AI OyPublished 6 October 2026

Tax

A Ab, a pawnbroking company granting loans against movable property, sold the pledge at auction when a borrower neither redeemed the pledged item nor renewed the loan before maturity. In connection with transferring a pledged item for sale at a pawn auction, A Ab charged the borrower four fees: a pawn-auction fee, a fee for transfer to the auction system, a fee for notification of surplus, and a fee for early sale of the security.Vero

The Central Tax Board held that, in light of the Court of Justice judgment in case C-89/23 (Companhia União de Crédito Popular), these fees cannot be regarded as consideration for the credit-granting service A Ab provided against the pledgeVero. The Court held that supplies relating to the organisation of auction sales of pledged goods are not ancillary to the principal supplies of granting pledge-secured credit, so they do not share the credit's VAT treatmentEuropa. The four fees must instead be regarded as consideration for a service the applicant provided to the borrower and which consisted in the sale of the item standing as security for the pawn loanVero; the decision states that this is a supply of a VAT-liable serviceVero. A Ab must therefore charge VAT on the pawn-auction fee, the fee for transfer to the auction system, the fee for notification of surplus, and the fee for early sale of the securityVero.

The distinction matters because financial services are VAT-exempt under section 41 of the VAT Act (Mervärdesskattelagen), with credit granting and other financing arrangements defined as financial services in section 42. Fees that are consideration for an exempt financing service escape VAT; fees for the separate, taxable auction-sale service do not. The decision also lists case C-94/19 (San Domenico Vetraria) among its legal bases.

The advance ruling applies for the period 21 August 2026 to 31 December 2027Vero and is not yet final (Ej lagakraftvunnen)Vero. It was published on 6 October 2026Vero.

Legal basis: Mervärdesskattelagen (1501/1993) 1 § 1 mom. 1 punkten, 18 § 2 mom., 41 §, 42 § 1 mom. 2 punkten, 190 a §; EU-domstolens dom i mål C-89/23; EUD:s dom i mål C-94/19.

Pawnbrokers charging auction-related fees on defaulted pledges should treat those fees as VAT-liable sales consideration and charge VAT, following the Board's distinction between credit and auction-sale services.

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