France joins day-one taxing list for hired-out labour in 2027

Wages that a foreign agency pays to a worker hired out to a Finnish user are taxable in Finland from the first working day when the treaty between Finland and the worker's home state contains a hired-labour clause.Vero From 2027 France joins that list under the new Finland–France treatyVero, which entered into force on 28 August 2026Vero and applies from 1 January 2027Vero.

The listed treaties let Finland tax hired-out labour without any 183-day stay.Vero The other states on the list are unchanged; Bulgaria has a wider clause that also covers non-agency situations where a Bulgarian resident works in Finland for someone other than a Bulgarian employer. Wages of a worker arriving from a state with no treaty with Finland are likewise taxable from the first day.

Day-one taxation triggers Finnish reporting even for short assignments.Vero A foreign employer that pays wages to a hired-out worker covered by a day-one clause files a start notification with the Incomes RegisterVero, with the estimated duration, the Finnish user and employer representative details and the estimated pay for the tax year, no later than the fifth calendar day after the first paydayVero. It also reports the wages paid. A Finnish user that hires foreign labour for work in Finland files a hirer notification for each foreign enterprise. The same filing logic applies to the new French cases from 2027: once the treaty lets Finland tax from day one, the start-notification and wage-reporting duties attach to French-resident hired labour as wellVero.

A separate 2026 boundary for Finnish vessels and aircraft now reads as 1 January 2026 or later.Vero From the start of 2026 a foreign employer reports start data and wages for a worker hired out from abroad to a Finnish vessel or aircraft referred to in Income Tax Act section 13 whenever Finland has a treaty right to tax the wage or there is no treaty.Vero The guidance clarifies that a start notification and a hirer notification are due for work performed on 1 January 2026 or later even where the assignment began in 2025 or earlierVero. The hirer notification for vessel and aircraft work rests on the same date rule.

Limited taxpayers remain under the special hired-worker procedure: assessment follows the ordinary timetable but at a flat 35 percent withholding rate, with a 510 euro monthly or 17 euro daily deduction for the working period and no other deductions, unless the worker claims progressive taxation under the source-tax rules. A worker on a Finnish vessel or aircraft seeks advance tax for the wage where the foreign employer has no Finnish permanent establishment, actual place of management or voluntary employer-register entry and no treaty bars collection, by the end of the calendar month following the month work began.

Firms using French-resident agency labour in Finland should diary 2027 for day-one withholding, Incomes Register filings and advance-tax requestsVero, and firms with vessel or aircraft assignments straddling the turn of 2025–2026 should treat 1 January 2026 itself as reportableVero.

Legal basis: Tuloverolaki 10 § 4 c kohta and 13 §, verotusmenettelystä annettu laki 15 a § and 17 § 7 momentti, laki tulotietojärjestelmästä 6 § 2 momentti and 12 § 8 momentti, rajoitetusti verovelvollisen tulon verottamisesta annettu laki 7 §, 13 § and 16 a §, and the Finland–France treaty applying from 1 January 2027.