SoomeVero
KVL: open-water swim package taxed at 13.5% as sports access
KVL:029/2026 treats a year-round lake-swim venue with sauna and lanes as one supply with sports access principal; 13.5% rate for 23.9.2026–31.12.2027.
Autor: Taxxa AI OyAvaldatud 14. oktoober 2026
Tegevusala: Operation of sports facilities
The Central Tax Board (KVL:029/2026)Vero treats a year-round open-water swimming venue's admission package as a single supply
Vero whose principal element is granting access to sports facilities
Vero — taxable at the reduced 13.5 per cent rate under section 85(1)(8) of the Value Added Tax Act
Vero (arvonlisäverolaki 1501/1993). The advance ruling covers 23 September 2026 to 31 December 2027
Vero and is not yet final (Ei lainvoimainen).
The package, sold for an admission fee labelled a swim ticket (uintilippu), gave access to open-water swimming in a delimited lake area all year roundVero. The company controlled a fenced-off water area with floating ropes and two buoy-laned 25-metre lanes, stated to match the swimming area of indoor pools. The ticket also covered sauna, dressing, washing and toilet facilities, swim belts, valuables lockers, three sunken hot-cold pools, a kept-open lit jetty walkway and a heated jetty. Three custom pumps kept the area ice-free in frost, and the company maintained the venue by clearing drifting litter, preventing slipperiness and servicing the jetties and the swimming-supporting technology.
The Board applied the average-consumer test from the Court of Justice case law cited in the ruling (Bastová C-432/15, C-215/19, Everything Everywhere C-276/09): viewed as a whole, the principal supply was the grant of access to premises suited to practising sport — swimmingVero — while the sauna, changing and washing facilities and the other specified components were merely means of enjoying the principal supply in the best conditions
Vero. The described services therefore formed one composite supply
Vero, with the outdoor pool's access right as the principal element
Vero, attracting the 13.5 per cent reduced rate for use of sports facilities under section 85(1)(8)
Vero.
The ruling's legal frame spans VAT Act sections 1(1)(1), 84 (the 25.5 per cent standard rate) and 85(1), Article 98(1) and Annex III of the VAT Directive, and the cited Court of Justice judgments. As an advance ruling for one company's described facts, it binds only that fact pattern and period — but it signals how KVL draws the principal-versus-ancillary line for bundled leisure venues.
Legal basis: arvonlisäverolaki (1501/1993), sections 84 and 85(1)(8); Council Directive 2006/112/EC, Article 98(1) and Annex III; KVL:029/2026 (advance ruling 23 September 2026–31 December 2027, not final).
Operators of bundled sports and leisure venues should test their packages against the principal-versus-ancillary test and confirm the applicable VAT rate before pricing.