Findings at a glance
- Traceability of the calculation
- Completeness of the data basis
- Business-specific benchmark
- Requirements for counter-evidence
- Burden of proof and its reversal
4× exceeded · 1× met
Traceability of the calculationexceeded
The comparison data on which the estimate is based must be shown to the taxpayer. Where that is not possible, the reason must be stated.
CitationLaki verotusmenettelystä (1558/1995) 27 §
What we provideEvery figure is traceable down to the individual document. The chain of calculation can be walked in both directions — from the result to the document and back.
Completeness of the data basisexceeded
In estimating income, the taxpayer’s activity and the comparison data or other available information are taken into account.
CitationLaki verotusmenettelystä 27 §
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
Before estimating, the authority must send a request to file the return or to provide an explanation, stating the estimated amount.
CitationLaki verotusmenettelystä 27 §
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 2 axes
Business-specific benchmarkexceeded
Estimation also applies where the declared income is manifestly too low compared with taxpayers in the same sector operating in similar circumstances.
CitationLaki verotusmenettelystä 27 §
What we provideThe calculation rests on the recipes and quantities of the audited business, not on an industry average.
Burden of proof and its reversalmet
Estimation applies where no return has been filed, where the return cannot serve as a basis even after correction, or where there is reason to suspect concealed income.
CitationLaki verotusmenettelystä 27 §
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.