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Authorised warehouse keepers and tax warehouses in excise taxation

An authorised warehouse keeper can manufacture products subject to excise duty and process, hold in possession, receive and dispatch such products under a duty suspension arrangement.

If the authorised warehouse keeper dispatches or receives alcohol, tobacco products or liquid fuels, it must use the Excise Movement and Control System (EMCS). When products are moved between warehouses in Finland, it is not mandatory to use EMCS. Instead, the simplified procedure may be used.

The activities take place in a tax warehouse and the excise duty is not filed and paid until later, when the products are released from the warehouse for consumption. The authorised warehouse keeper is also tax-liable for any product loss in the tax warehouse.

The manufacturer of products subject to excise duty usually needs an authorised warehouse keeper’s authorisation. However, small producers of soft drinks and beverage containers do not need the authorisation.

A reliable wholesale company can be granted an authorised warehouse keeper’s authorisation if it trades regularly in products subject to excise duty. After the grant of an authorisation, the wholesaler can keep a tax warehouse. Tax-free shops at airports also need a tax warehouse authorisation.

Authorised warehouse keepers can conduct activities according to the authorisation only in tax warehouses. A tax warehouse authorisation is granted at the same time as an authorised warehouse keeper’s authorisation requested by the warehouse keeper.

If the authorised warehouse keeper is declared bankrupt, tax-liability rests with the party that releases products from the tax warehouse for consumption after the bankruptcy. In practice, the party is usually the bankruptcy estate.

Who can be granted an authorised warehouse keeper’s authorisation?

A condition for the grant of an authorised warehouse keeper’s authorisation is that the applicant

  • produces or processes products subject to excise duty
  • engages in continuous and extensive wholesale trading of products subject to excise duty
  • continuously and extensively uses products subject to excise duty for tax-exempt purposes under the Excise Duty Act or releases products subject to excise duty for use in tax-exempt purposes
  • runs a shop of tax-free products
  • rents a storage space or storage services for the conduct of activities that qualify for an authorisation.

An authorisation may also be granted for other activities similar to those mentioned in the above list.  

What kind of warehouse qualifies for a tax warehouse authorisation?

A tax warehouse authorisation can be granted if

  • the warehouse, space or area is in the applicant’s possession and can be controlled by authorities
  • the warehouse is suited to the activities for which the applicant has received an authorised warehouse keeper’s authorisation, and the warehouse is actually used for these activities
  • there is an acceptable and a justified need for keeping the warehouse.

General conditions for an authorisation

The Tax Administration grants an authorisation if the applicant has attended to their tax-related obligations without negligence and has paid a guarantee related to the authorisation. The authorisation must be valid during the company’s activities subject to excise taxation.

No authorisation is granted if the applicant

  • has a ban on business operations
  • is a corporate entity or partnership whose director has a ban on business operations
  • has substantially neglected or – based on their previous negligence – can be expected to neglect their accounting or taxation obligations
  • is bankrupt.

The applicant must be an adult and their competency may not be limited.

If the application concerns alcohol products, the applicant also has to contact the National Supervisory Authority for Welfare and Health (Valvira) in order to obtain the licences required by alcohol legislation.

A guarantee for the payment of excise duties

Before an authorisation is granted, the applicant must deposit a guarantee, specified by the Tax Administration, for the payment of excise duties. The guarantee is chiefly required if the authorisation concerns products subject to harmonised excise duty in the EU. Such products include alcohol, liquid fuels and some tobacco products.

Guarantees in excise taxation (available in Finnish and Swedish, link to Finnish)

The authorisation decision is subject to a fee

In the authorisation decision, the Tax Administration confirms the conditions which are essential for purposes of control and taxation and which the authorisation holder must comply with. The decision is subject to a fee.

List of fees charged for certain Tax Administration services (available in Finnish and Swedish, link to Finnish)

For alcohol products, other licences are also needed. Further information is available from Valvira, the National Supervisory Authority for Welfare and Health

How to request an authorisation

Request an authorised warehouse keeper’s authorisation and a tax warehouse authorisation in MyTax. The processing of the application usually takes several months.

How to apply for an authorised warehouse keeper's authorisation in MyTax

Request an authorisation in MyTax

Further information

Key terms:

Page last updated 11/11/2022