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FinlandVero

City studio leases count as taxable property leasing, no refund

KVL holds a city operator model for 55 art studios is VAT-scope leasing under AVL 130(2), blocking the municipal input-VAT refund.

By Taxxa AI OyPublished 13 November 2026

Tax

Industry: Renting and operating of own or leased real estate

A city's letting of 55 studios in a new building for art activity is leasing for consideration within the scope of VATVero. The studios were to be let on long-term leases to art-sector operatorsVero, with letting handled by an operator under a usage-right agreement with the cityVero. The city itself was to set the rent charged for the studios at no more than 10 euro per square metreVero, split so the city kept a 4.5 per cent shareVero, and the revenues from the building were expected to cover about 10 per cent of the costs of arranging the art premises.

On those facts, the activity is real-property leasing within Arvonlisäverolaki 130 § 2 momenttiVero. Because the acquisitions relate to that leasing activity, the city has no right to the municipal refund in Arvonlisäverolaki 130 § 1 momentti for VAT included in acquisitions for the activityVero. Municipal advisers must therefore treat input VAT on the studio-letting chain as unrecoverable through the municipal refund, even though the lessor is a cityVero.

The assessment turns on consideration and VAT scope: the studio letting was held to take place for considerationVero and to constitute leasing activity within VAT scope under Arvonlisäverolaki 1 §, 6 § and 27 §Vero, with deduction and the municipal refund decided under 102 § and 130 §Vero.

The advance ruling covers 23 September 2026 to 31 December 2027Vero. It is not finalVero; it has been appealedVero. Advisers with identical municipal studio or cultural-premises lettings should track the appeal before relying on the rulingVero.

The ruling is KVL:032/2026Vero, and the judgments named alongside the VAT Directive are C-215/19 Veronsaajien oikeudenvalvontayksikkö (Konesalipalvelu) and C-263/15 LajvérVero. Legal basis is Arvonlisäverolaki 1 §, 6 §, 27 §, 102 §, 130 § 1 and 2 momentti and 190 a §Vero, with Council Directive 2006/112/EC Article 135(1)(a) and judgments C-215/19 and C-263/15 as citedVero Vero.

Sources

KVL:032/2026 - vero.fi