The collection of comparison data by the Finnish Tax Administration’s (“FTA”) has become increasingly common in recent years as part of efforts to strengthen tax control. Collection of comparison data refers to a tax audit that aims to collect information relating solely to other taxpayers for the purpose of determining the tax position of another taxpayer, such as the customers or business partners of the entity being audited.
On 5 September 2025, the Helsinki Administrative Court issued a significant ruling (5366/2025), in which it found that the Adjustment Board had rightfully, on the basis of data protection legislation, overturned the FTA’s requests for comparison data from a bank. The FTA’s information requests were not considered proportionate or necessary for their purposes as required by EU’s General Data Protection Regulation and the Finnish Data Protection Act. The Administrative Court’s decision emphasises that data protection requirements must be fully observed in the collection of comparison data by the FTA.
Read the article in Finnish: Hallinto-oikeuden päätös 5.9.2025: Tietosuojavaatimukset rajoittavat Verohallinnon vertailutietotarkastusten laatua ja laajuutta