Benefits: recovery and recourse

Example 4: The income earner has received a housing allowance of EUR 400 for the period 1 August–15 September 2023. At the same time, he has received an adjusted daily allowance. In May of the next year, it is discovered that excessive housing allowance has been paid, to the amount of EUR 128. The income earner is now employed, so no more daily allowance is paid. The overpayment has been recovered with an invoice. However, the income earner has not paid the invoice sent to them, and the invoice is now being recovered through enforcement. The employer has collected the enforcement fee from the employee's wages and paid it to the enforcement authorities. Enforcement has paid the amount to the benefit payer 2 December 2024. Although the payment was recovered by way of enforcement, the report on recovery is submitted in the same way as if the income earner had paid the payment back to the benefit payer himself. The benefit payer has reported the housing allowance to the Incomes Register, and also submitted an unjust enrichment report after noticing the overpayment.

The new report submitted for the recovery:

Example 5: Recovery has been partly too high. The submitted report is corrected. On 28 March 2023, the income earner returned the benefit income overpaid in February 2022 to the benefit payer. The payer submits a report on the recovery to the Incomes Register on 31 March 2023. The amount of the recovery is EUR 50.00. The income earner’s tax rate for the original payment was 10%. The benefit unit (number of days) must be entered if a benefit for which this information is mandatory is paid. Table 1 includes the payer’s original report on the recovery.

The benefit payer later notices that the recovered amount was incorrect. The recovered amount was EUR 50, even though only EUR 33.60 should have been recovered. The payer refunds the unnecessarily recovered share to the income earner and submits a replacement report with correct information to the Incomes Register. In this example, the repayment and the refund of the recovered amount to the income earner take place during the same tax year. The benefit unit (number of days) must be entered if a benefit for which this information is mandatory is paid. Table 2 shows the replacement report.

Because the repayment and the refund of the recovered amount to the income earner take place in the same tax year in the example, the new payment is not reported to the Incomes Register.

If the payer only refunds the recovered payment after the end of the tax year, the payer leaves the recovery report unchanged and submits a new report for the new payment, also including the ‘Payment reallocation: Yes’ entry. If the payment was originally taxable, tax must be withheld from the new payment.

Example 6: On 28 March 2023, the income earner returned the benefit income overpaid in February 2022 to the benefit payer. The payer submits a report on the recovery to the Incomes Register on 31 March 2023. The amount of the recovery is EUR 50.00. The benefit unit (number of days) must be entered if a benefit for which this information is mandatory is paid. Table 1 includes the payer’s original report on the recovery.

The benefit payer later notices that the amount should not have been recovered at all. The payer refunds the unnecessarily recovered amount to the income earner and cancels the submitted report. Table 2 shows information about the cancellation.

Because the repayment and the refund of the recovered amount to the income earner take place in the same tax year in the example, the new payment is not reported to the Incomes Register.

If the payer only refunds the recovered payment after the end of the tax year, the payer leaves the recovery report unchanged and submits a new report for the new payment, also including the ‘Payment reallocation: Yes’ entry. If the payment was originally taxable, tax must be withheld from the new payment.

Example 7: The income earner was paid a benefit of EUR 1,000. A report on the income is submitted to the Incomes Register. In the example, a benefit is paid for which entering the benefit unit is mandatory. The example also applies to other benefits, in which case reporting the unit is voluntary. Table 1 shows the benefit payer’s report on the original payment:

The entire benefit is later stated as an unjust enrichment, and the payer submits a replacement report for the full amount to the Incomes Register. The ‘Unjust enrichment: Yes’ data is entered on the report. Because the situation concerns an unjust enrichment, zero (0) days are reported as the benefit unit on the replacement report.

Table 2 shows a report on which the original benefit is changed to an unjust enrichment. The following data is entered on the report: ‘Unjust enrichment: Yes’, days 0.

The income earner repays part of the benefit (EUR 300) in March. On the recovery report, 0 is entered as the benefit unit. Table 3 shows the recovery report submitted by the benefit payer.

As a result of a later decision issued at a court of law, the benefit payer’s decision is cancelled and the income earner’s right to the benefit resumes. Because the income is no longer an unjust enrichment, the submitted report has to be corrected so that the units (days) are given as original values.

Because the income earner has already returned part of the amount in this example, the income amount is divided into two parts on the report. Information about the unjust enrichment is removed from the part which the income earner has not returned, and the information is left unchanged regarding the part of the income which the income earner has returned to the payer. The number of days is indicated regarding the part of the income, from which the information about the unjust enrichment is removed on the replacement report.

The payer pays the unjustifiably collected EUR 300 to the income earner. The payer submits a new report on the new payment with a new payment date. The benefit unit is reported as 0, because the days were indicated on the replacement report. Table 5 shows the benefit payer’s report on the new payment:

Adjusted unemployment benefits are reported similarly. The number of days is corrected in the case of a partial recovery and the number of days decreases. More detailed instructions on how to report adjusted days are given in the instructions ‘Benefits – Reporting data to the Incomes Register’.

Example 8: The income earner was paid a benefit of EUR 100. A report on the income is submitted to the Incomes Register. The entire benefit is later stated as an unjust enrichment, and the payer submits a replacement report for the full amount to the Incomes Register. The ‘Unjust enrichment: Yes’ data is entered on the report. In addition to the replacement report, the payer submits a new report on recovery. The benefit unit (number of days) must be entered if a benefit for which this information is mandatory is paid.

As a result of a later decision issued at a court of law, the benefit payer’s decision is cancelled and the income earner’s right to the benefit resumes. The income earner has returned the full overpayment to the payer. The payer submits a new report on the new payment with a new payment date. Any previously submitted reports do not need to be changed.

Table 1 shows the benefit payer’s report on the original payment:

Table 2 shows a report on which the original benefit is changed to an unjust enrichment. The following data is entered on the report: ‘Unjust enrichment: Yes’.

The income earner repays the benefit in March. Table 3 shows the recovery report submitted by the benefit payer.

When the conditions later change, the benefit payer pays the unjustifiably collected income to the income earner. Table 4 shows the benefit payer’s report on the new payment:

Example 9: The income earner was paid a benefit of EUR 2,500. The income is reported to the Incomes Register. The example shows a benefit for which reporting the benefit unit is mandatory. The example can also be applied to other benefits, in which case reporting the unit is voluntary. The report on the original payment submitted by the benefit payer is shown in Table 1:

Part of the benefit (EUR 300) is later found to be unjust enrichment and the payer submits a replacement report to the Incomes Register. ‘Unjust enrichment: Yes’ must be entered on the report. In the replacement report, zero (0) days is given as the benefit unit of the unjust enrichment.

A report in which part of the benefit is changed to unjust enrichment is shown in Table 2. The following data must be entered on the report: ‘Unjust enrichment: Yes’, days 0.

The income earner repays the unjust enrichment in March. In the recovery report, 0 is given as the benefit unit. The recovery report submitted by the benefit payer is shown in Table 3.

The decision made by the benefit payer is overturned by a court and the income earner is again entitled to the benefit. As the income earner has already repaid the unjust enrichment, a replacement report is not required and the unjustly recovered part is returned to the income earner and a new report on the payment is submitted to the Incomes Register. The payer may also submit a replacement report, in which case the benefit unit data is reported in accordance with Tables 5 and 6.

The payer submits a new report on a new payment with a new payment date. Three days is given as benefit unit data because the 17 days already reported are still valid. The report on the new payment submitted by the benefit payer is shown in Table 4:

Alternative reporting method: The decision made by the benefit payer is overturned by a court and the income earner is again entitled to the benefit. As the income is no longer unjust enrichment, the report already submitted must be corrected and the original benefit unit dates must be given.

The income given in the report is divided in two parts: The unjust enrichment data is left in the part that the income earner has repaid to the payer. The number of days is given in the part that is not unjust enrichment.

The payer pays the unjustly recovered EUR 300 to the income earner. The payer submits a new report on a new payment with a new payment date. Zero (0) is given as benefit unit data because the dates have been submitted on a replacement report. The report on the new benefit submitted by the benefit payer is shown in Table 6:

Example 10: The income earner was paid a benefit of EUR 100. A report on the income is submitted to the Incomes Register. The entire benefit is later stated as an unjust enrichment, and the payer submits a replacement report for the full amount to the Incomes Register. The ‘Unjust enrichment: Yes’ data is entered on the report. The benefit unit (number of days) must be entered if a benefit for which this information is mandatory is paid.

As a result of a later decision issued at a court of law, the benefit payer’s decision is cancelled and the income earner’s right to the benefit resumes. As the income earner has not yet returned the payment, the payer submits a new replacement report and removes the ‘Unjust enrichment’ entry given on the previous replacement report.

Table 1 shows the benefit payer’s report on the original payment:

The income is deemed unjustified, and the payer corrects the ‘Unjust enrichment’ entry on the report:

When the conditions change, the income earner is once again entitled to the benefit. As the income earner has not yet repaid the income, the payer replaces the previously submitted replacement report by submitting another replacement report. The ‘Unjust enrichment’ entry is removed from the report.

Example 11: The income earner has received a benefit retroactively for the period 1 February – 30 April 2023 (EUR 1,000 per month). The benefit for three months was paid as a lump sum on 5 May 2023. Of the amount of EUR 3,000, the employer received EUR 2,400 (EUR 800 per month). Since the deduction type is ‘Other deduction from taxable income’, the income earner received EUR 600 as taxable income.

It is later found that the share of the benefit for April paid retroactively on 5 May (EUR 1,000) was an unjust enrichment, and the payer submits a report on the unjust enrichment. The share paid to the income earner (EUR 200) is reported as an unjust enrichment. The share of the unjust enrichment paid to the substitute recipient (EUR 800) is not reported to the Incomes Register. The payer reports the recovery data to the Incomes Register when the income earner has returned the overpayment to the payer. The returned amount paid by the substitute recipient is not reported to the Incomes Register.

The example (Table 1) presents the report submitted for May, indicating the payment of EUR 2,400 to the substitute recipient. According to the tax card, 20% tax has been withheld from the income earner. The actual income type paid (benefit B) is used as the income type of the deduction, because the income type (wages) paid by the substitute recipient to the income earner is not available on a benefits payment report.

The example (Table 2) presents a replacement report in which the income earner’s share of the overpayment is reported as an unjust enrichment. The amount of the benefit shall be corrected to EUR 2,000, and the amount reported as deduction is the amount that should be left to the substitute recipient.

When the income earner returns an unjust enrichment, the benefit payer must report recovery data to the Incomes Register (Table 3).

Example 12: The income earner was paid national pension amounting to EUR 220 per month for the period 1 January–31 May 2023 (totalling EUR 1,100). However, only a pension of EUR 200 per month should have been paid (totalling EUR 1,000). A total of EUR 100 has been paid in excess pension over a period of 5 months. The income earner's withholding percentage is 5. The error is corrected in the August pension payment.

The example of a report (Table 1) features the report submitted to the Incomes Register in January, and corresponding reports are submitted for February–May:

When the benefit payer notices an error or a decision has been made regarding an unjust enrichment, the benefit payer submits the replacement reports for January–May. The example of a report (Table 2) features the replacement report for the January report, indicating the unjust enrichment:

Recovery is carried out in connection with the August payment of the national pension by offsetting the overpayment, i.e. EUR 100, from the EUR 200 pension paid. Tax is withheld from the gross amount paid, EUR 100 (200 – 100).

The example of a report (Table 3) features the report submitted in August, indicating the offsetting of the income:

Example 13: The income earner has been paid EUR 310 of housing allowance in January. In March, it is found out that no housing allowance should have been paid at all. An agreement has been made with the income earner of the housing allowance being offset in four instalments from the parental allowance of EUR 400 per month paid in the same year (withholding rate 25%). The housing allowance is tax-exempt and the parental allowance is taxable. The payer carries out the first offset in April.

The example of a report (Table 1) features the report submitted in January:

Once the error has been detected or a decision on unjust enrichment has been made, the benefits payer submits a replacement report for January. The example of a report (Table 2) features the replacement report indicating the unjust enrichment:

The first recovery is carried out in April by offsetting EUR 77.50 (310 ÷ 4) of the housing allowance from the parental allowance. Because the parental allowance is taxable and the housing allowance is tax-exempt, withholding is calculated from the entire parental allowance amount. As a result, withholding is EUR 100 (400 × 0.25). For family leave income types, the Benefit unit data is mandatory regarding benefits paid after 1 January 2023, which means that the number of days must be reported to the Incomes Register.

The example (Table 3) presents a report submitted in April for offsetting tax-exempt income from taxable income:

Example 14: On 4 March 2023, the income earner was paid a labour market subsidy for February. A total of EUR 648 of subsidy was paid for 20 days. 20% tax has been withheld from the labour market subsidy. In May, it is found out that the labour market subsidy should have been paid for only 15 days in February (EUR 486). The gross amount to be recovered is thus EUR 162. In June, the income earner is paid EUR 480 of housing allowance, and it has been agreed that the overpayment is offset from the housing allowance. The labour market subsidy is taxable and the housing allowance is tax-exempt.

The example of a report (Table 1) features the report submitted in March:

The example of a report (Table 2) features the replacement report indicating the unjust enrichment. Because this is unjust enrichment, zero (0) is reported as the number of benefit units:

Because the later payment is tax-exempt, only the net amount paid is offset from the income earner, or EUR 129.60 (withholding EUR 32.40).

The example of a report (Table 3) features the report submitted in June, in which taxable income is offset from tax-exempt income:

Example 15: After the death of her spouse, the income earner has been paid EUR 450 per month in State artist pension as a survivors' pension. The artist pension was granted to the spouse prior to 1 January 1984, so the pension has been tax-exempt for its recipient. The income earner herself has retired, and the pension amounts have been revised. On 5 April 2023, the benefit payer has made a decision according to which only EUR 420 per month of survivors' pension should have been paid from January 2023 onwards. The recovery is carried out so that the benefit payer offsets EUR 30 in pension overpayment each month from the pensions it pays in May-August.

The example (Table 1) presents a report submitted to the Incomes Register in January, and corresponding reports have been submitted for February and March. When reporting the income type, it is mandatory to report the taxability of the benefit.

The example of a report (Table 2) features the replacement report submitted for January, in which the unjust enrichment is indicated. Corresponding reports have been submitted for February–April.

The example of a report (Table 3) features the report submitted in May, in which the offsetting of the income is indicated. Corresponding reports have been submitted for June–August.

Example 16: On 3 February 2023, the benefit payer has paid the income earner EUR 1,100 in pension for February (withholding rate 22%, i.e. EUR 242). In December 2023, it is noticed that EUR 100 was overpaid in February. The benefit payer submitted a replacement report to the Incomes Register in December, reporting EUR 1,000 as the amount of pension paid in February and EUR 100 as an unjust enrichment (EUR 1,100 in total).

In January 2024, the income earner receives a pension of EUR 1,000, from which EUR 200 are withheld in taxes (20%). The benefit payer and income earner have agreed that the benefit payer offsets the overpaid 2023 pension of EUR 100, from which EUR 22 were withheld in taxes.

The benefit payer withholds EUR 200 (20%) from the entire EUR 1,000, because the entire amount was taxable income in the repayment year. The payer deducts the net overpayment of EUR 78 (gross EUR 100, withholding EUR 22) from the remaining EUR 800, and pays EUR 722 to the income earner.

The example presents a report submitted in January:

The previous example 16 can also be applied in situations, where there is no benefit left to pay to the income earner after the payer's offset.

Example 17: The benefit payer has paid the income earner an earnings-related allowance and a child increase to it (EUR 5.23 per day) during the period 1 March 2023–31 May 2024. In June 2024, it is discovered that there have been no grounds for payment of the child increase. The benefit payer has submitted reports on the payments to the Incomes Register. In June 2024, the benefit payer submits replacement reports in which the payer reports the child increases paid as unjust enrichment. An agreement is made with the income earner that the child increase is recovered in three instalments. The overpayment of child increase is recovered from the earnings-related allowances paid from July 2024 onwards.

The benefit payer has paid the child increase as follows:

• Year 2023: 1 March–15 December 2023 the benefit was paid for 211 days, totalling EUR 1,103.53
• Year 2024: 16 December 2023–31 May 2024 the benefit was paid for 116 days, totalling EUR 606.68.

The amount to be recovered totals EUR 1,710.21, and it is recovered as follows:

• 1st instalment: EUR 570.07 is offset from the earnings-related allowance paid on 11 July 2024 (109 days, earnings period 1 March–31 July 2023). The earlier payments were made during the period 31 March–31 July 2023.
• 2nd instalment: EUR 570.07 is offset from the earnings-related allowance paid on 12 August 2024:
  • EUR 533.46 (102 days, earnings period 1 August–15 December 2023). The earlier payments were made during the period 31 August–21 December 2023.
  • EUR 36.61 (7 days, earnings period 16 December–31 December 2023). The earlier payment was made on 15 January 2024.
• 3rd instalment: EUR 570.07 is offset from the earnings-related allowance paid on 11 September 2024 (109 days, earnings period 1 January–31 May 2024). The earlier payments were made during the period 14 February–5 June 2024.

Tax of 20% was withheld from the income earner’s income between 1 March2023 and 31 January 2024. Since the beginning of February 2024, the withholding rate has been 24%.

Because the recovery is only carried out from July 2024 onwards, the recovery can no longer be taken into consideration in the income earner’s 2023 taxation. The payments paid in 2023 are recovered as gross amounts. Instead, the payments paid in 2024 can be recovered as net amounts (see Section 2.2.1 for net recovery and Section 2.2.2 for gross recovery).

The example (Table 1) presents a report on the offsetting of income submitted in July:

The benefit payer withholds 24% tax from the full amount of earnings-related allowance (2,363.76 × 0.24). EUR 570.07 of child increase is recovered from the amount remaining after the withholding, i.e. EUR 1,796.46. The income earner is paid EUR 1,226.39. The Finnish Tax Administration takes the recovered amount into account in 2024 as a recovery deduction.

Child increases paid in both 2023 and 2024 are offset from the earnings-related allowance for August. For the taxation to be correct, the recovery data must be submitted separately for each year. The 2023 child increase for the period 1 August–15 December 2023 (102 days, EUR 533.46) was paid in 2023, so it is recovered as a gross amount. This recovered payment is taken into account in the taxation for the payment year as a recovery deduction. The child increase for the period 16 December–31 December 2023 (7 days, EUR 36.61) was paid in 2024, so it is taken into account in the taxation by deducting the share from the amount of child increase for 2024.

The example of a report (Table 2) features the report of the offset submitted in August:

The benefit payer withholds tax from EUR 2,439.71 (the overpayment EUR 36.61 paid in 2024 is deducted from the EUR 2,476.32), because this amount is taxable income for the repayment year. The benefit payer deducts the offset amount, EUR 570.07 (gross EUR 533.46 + 36.61), from the remaining EUR 1,890.79 and pays EUR 1,320.72 to the income earner. The Finnish Tax Administration takes EUR 533.46 into account as a recovery deduction and deducts EUR 36.61 from the income earner's taxable income for 2024.

The example of a report (Table 3) features the report of the offset submitted in September 2024:

The recovery is carried out by offsetting the overpayment of EUR 570.07 from the earnings-related allowance, i.e. EUR 2,701.44. Withholding (24%) is done from the gross amount to be paid, i.e. EUR 2,131.37.

Example 18: On 5 July 2023, the benefit payer pays the income earner EUR 540 of labour market subsidy for the period 1 June –30 June 2023 (withholding 20%). The payer recovers EUR 25 of taxable study grant and EUR 30 of tax-exempt housing allowance paid in 2018 from the labour market subsidy.

The housing allowance and the study grant have not been reported to the Incomes Register, as they are income for the year 2018.

The example of a report features the report of the offset submitted in July:

The entire amount of the labour market subsidy, or EUR 540, is taxed as income for the year 2023. The income earner gains a recovery deduction for the year 2023 from the recovered study grant. Because the housing allowance is tax-exempt income, its recovery has no effect on taxation.

Example 19: The income earner has received an unemployment allowance of EUR 1,500 for the period 2 March – 1 April 2023. The payment date is 06/04/2023. A retroactive disability pension starting from 01/03/2023 is granted to the income earner on 05/07/2023. The amount of the disability pension is EUR 800 per month, and it is paid as a lump sum for the period 1 March – 31 July 2023 (totalling EUR 9,000). The unemployment allowance is recovered so that the payer of the disability pension pays an unemployment allowance of EUR 1,500 from the retroactive pension of EUR 1,800 for March and April to the payer, in which case the income earner receives a total of EUR 7,500 (gross) for the entire period.

The example (Table 1) presents the unemployment allowance payer’s report for April:

The example (Table 2) presents the report submitted by the payer of the later benefit, i.e. the disability pension, in July:

When the payer of the unemployment benefit has received the recourse payment, the payer submits a replacement report to the Incomes Register. The payer enters the information "Recourse – Yes” on the replacement report. When paying the basic component of the earnings-related allowance, the benefit unit must be specified. This data is also mandatory on the replacement report (Table 3):

Example 20: The income earner has received a labour market subsidy of EUR 500.01 (gross) per month for the period 1 April 2023–1 March 2024. On 4 April 2024, the income earner is granted a retroactive disability pension of EUR 450 per month (gross) for the same period. The benefits are paid simultaneously to the income earner, so the earlier paid labour market subsidy creates an overpayment of EUR 50.01. However, this overpayment is not recovered from the income earner.

The example of a report (Table 1) features the May report submitted by the payer of the labour market subsidy. The payer submits a similar report for each month, specifying the labour market subsidy paid.

The payer of the disability pension submits a report to the Incomes Register of the retroactive disability pension paid on 4 April 2024 for the period 1 April 2023–31 March 2024 (Table 2). The payer also reports the disability pension for April 2024 it paid on the same day. The amounts paid as recourse are shown in the Deductions data group. Although the disability pension is paid as a continuous income, "One-off remuneration – Yes" must be specified, as income is paid retroactively for a period of more than three months before the beginning of the tax year.

When the payer of the labour market subsidy receives a recourse payment from the payer of the disability pension, the payer of the labour market subsidy submits a replacement report for May 2023 to the Incomes Register (Table 3). The recourse payment of EUR 450 received and the overpayment of EUR 50.01 that has changed into unjust enrichment are reported on the replacement report. The payer also submits a corresponding replacement report for the other months. Because unjust enrichment is in question, zero (0) is reported as the benefit unit. The data must not be removed from the replacement report, as it is required by the data users.

Example 21: The income earner was paid EUR 1,500 of sickness daily allowance for the period 1 April–30 April 2023. In August 2023, the same benefit payer grants the income earner a retroactive disability pension of EUR 1,800 per month from 1 April 2023 onwards. The disability pension is paid instead of the sickness allowance. The benefit payer collects the sickness allowance it previously paid for the same period from the disability pension (internal recourse).

Because the earlier payment and the later payment are both taxable, section 112 a, subsection 3 of the act on income tax is applied. The payment made later (the disability pension) is therefore not taxable income to the extent it is paid to the payer of the earlier benefit (sickness allowance). The earlier payment remains taxable income.

The benefit payer deducts the gross amount of the earlier payment (amount from which tax has not been withheld) from the gross amount of the payment made to the income earner later. EUR 1,500 of sickness allowance recourse is thus deducted from the retroactive EUR 1,800 pension. In August, the benefit payer also pays the disability pension for April-August.

The example of a report (Table 1) features the benefit payer's May report of the sickness allowance:

The benefit payer pays the disability pension retroactively for the period 1 April–31 August 2023. A new report must be submitted to the Incomes Register for this payment (Table 2). The recourse deductions are reported in the Deductions data group.

When the benefit payer receives the recourse payment, the payer submits a replacement report and specifies "Recourse – Yes" (Table 3).

Example 22: A pension provider has granted an income earner a rehabilitation allowance for the duration of the income earner’s unpaid work try-out period from 1 September 2023 to 30 September 2023. The rehabilitation allowance was paid directly to the income earner. The payment of the rehabilitation allowance is based on the income earner’s work try-out. The pension provider has taken out accident insurance for the duration of the work try-out period. The income earner is an accident during the work try-out period on 25 September 2023.

A company paying compensation for traffic accidents and other accidents grants the income earner a benefit based on the accident. The company does not pay the benefit directly to the income earner; instead, it pays it to the earnings-related pension provider based on the insurance policy the pension provider has. The share of the rehabilitation allowance is paid to the pension provider.

The pension provider submitted a new report on the rehabilitation allowance before the accident.

In the example (Table 1), a report was submitted in September on the rehabilitation allowance paid directly to the income earner:

After the accident, the traffic accident and accident compensation company pays the granted benefit to the pension provider.

As an exception, the deduction type is reported as ‘Other deduction from taxable income’. Usually, the deduction type ‘Other deduction from taxable income’ is only used for payments made to employers or bankruptcy estates. The situation in this example forms an exception.

Table 2 shows the report issued by the traffic accident and accident compensation company on the benefit it granted:

Example 23: The income earner became unemployed on 1 December 2022. The benefit payer has paid EUR 2,228 of social assistance to the income earner during the period 1 January 2023–15 March 2023 against the upcoming earnings-related allowance. On 23 March 2023, the unemployment fund pays the income earner a total of EUR 4,800 of earnings-related allowances for the period 5 December 2022–15 March 2023, of which amount it pays EUR 2,228 to the earlier benefit payer.

The social assistance is not reported to the Incomes Register.

In March 2023, the unemployment fund submits a report to the Incomes Register:

The unemployment fund must submit the data to the Incomes Register and also submit an annual information return to the Tax Administration regarding unemployment benefit days in 2022.

Example 24: In July 2023, the income earner is paid a tax-exempt benefit retroactively for the period 1 April – 30 April 2023. A taxable benefit has been paid earlier for the same period. The payer of the taxable benefit has made a recourse claim of EUR 200. The amount of the tax-exempt benefit paid is EUR 600. Of this amount, EUR 200 are paid to the payer of the earlier benefit as a recourse and EUR 400 are paid to the income earner. The example (Table 1) presents the payer’s report on the tax-exempt benefit, taking the recourse claim into consideration:

In order for the Finnish Tax Administration to receive information on the taxable benefit having been recovered as a recourse on the tax-exempt income, the payer of the taxable benefit must include the "Recourse from tax-exempt income, payment date" entry in addition to the "Recourse – Yes" entry. Based on this data, the income earner is correctly taxed, and only the part of the taxable benefit that was not recovered as a recourse on tax-exempt income becomes taxable income.

The "Recourse from tax-exempt income, payment date" entry does not have to be reported on the replacement report if the recipient of the recourse payment has not received the information in question from the payer of the recourse payment. Information not available to the report submitter cannot be reported to the Incomes Register.

The example of a report (Table 2) features the replacement report submitted by the payer of the earlier benefit after the payer has received the recourse payment. The recourse payment was made to the payer of the earlier benefit on 1 July 2023. The payment shows on the recipient's account on 3 July 2023 and is allocated in the recipient's system on 5 July 2023:

Example 25: On 10 April 2023, the income earner has been paid EUR 1,200 of taxable benefit for the period 2 March–1 April 2023. EUR 300 has been withheld from the benefit. Later, a taxable pension of EUR 500 and a related tax-exempt supplement of EUR 30 are granted for the same period. The payer of the taxable benefit paid earlier has made a recourse claim of EUR 530.

The example of a report (Table 1) features the report submitted by the payer of the benefit paid later:

The payer of the benefit paid earlier submits a replacement report, in which the payer includes the "Recourse – Yes" entry. Additionally, the payer reports the "Recourse – Yes" entry for the payment received from the tax-exempt income as well as the "Recourse from tax-exempt income, payment date" entry. Because the benefit payer has received recourse payments for both taxable and tax-exempt income, the recourse payments must be itemised as follows (Table 2):