Providing the trader details

The company is regarded as established in the customs territory of the EU if any of the following is located in the customs territory of the EU (UCC Art. 5):

• registered office
• central headquarters
• permanent business establishment

The company’s permanent business establishment means a fixed place of business, where both the necessary human and technical resources are permanently present for carrying out transactions. Furthermore, Customs must be able to carry out customs related operations via this establishment. A business establishment in an EU country cannot be considered permanent, if the company only has occasional activity there or has personnel working occasionally (e.g. a project manager).

Multinational company

A multinational company or group of companies can have several other offices in addition to the parent company. If you are using the office of a multinational company or a group of companies as declarant in the customs declaration, find out if the company or office is established in the customs territory of the EU:

• If the multinational company or group of companies are their own legal entities, each legal entity can be registered as their own places of business in the EU country in question. The legal entity can act or be a party in the customs transactions, for example make a customs declaration. The legal entity has registered itself in Finland in the business register, for example as a limited company.
• If the offices of a multinational company or a group of companies are not their own legal entities, rather the parent company only is regarded as a legal entity, the EORI number will only be granted to the parent company. In that case, all these other offices use the parent company’s EORI number. Please note that if the parent company is established outside the EU, but is active in several EU countries, the parent company is regarded as established in the customs territory of the EU. However, check if the parent company and the offices need to be registered in the Member State.

In which country should you register for EORI?

The company must apply for the EORI number and registration in the EU country where it is established.

If the company is not established in the customs territory of the EU, it must apply for the EORI number from the customs authority of the EU country, where the company lodges its first declaration or applies for a decision. In the future, the company must use the EORI number it obtained from the first EU country, even when it conducts business in other EU countries. (Union Customs Code Article 9)

Read more about the EORI number and how to apply.

If a company is not established in the EU territory, but it has a Finnish EORI number

The EORI number applied for from Finland, by a company not established in the EU territory, can be identified by its format. EORI numbers granted in Finland begin with Finland’s country code, followed by the country code of the country where the company is established. For example, if a Norwegian company not established in the EU territory applies for an EORI number from Finland, the EORI number granted begins with FINO followed by a number sequence. The official definition of the EORI number is that it begins with the two-letter country code and has at most 15 characters, which can be letter and numbers. However, the number may be shorter and there is no uniform EU policy on the format of the EORI number.

Please note the following before you submit a declaration with a foreign EORI number:

• Even though the company is not established in the EU territory, it can receive a Finnish VAT number, which is provided as additional fiscal information with the code FR1. However, the company must always provide the EORI number in the customs declaration.
• The headquarters of a group of companies can e.g. be located outside the EU territory, but the company can still be established in Finland and receive a Finnish EORI number, if the company has an office in Finland. In that case, the EORI number consists only of the Finnish country code followed by the business ID. If the office is established in Finland, the EORI number has the format FI + Business ID (e.g. FI1234567-8).
• Even if the company has a Finnish business ID but no office in Finland, instead, the office is established in another EU country; in that case, the EORI number is applied for from the other EU country where the company has an office.
• If the company already has been granted an EORI number and you receive a new VAT number from another country, remember to link it to the granted EORI number. If you are only now applying for an EORI number, remember to enter in the application all the VAT numbers that you use in EU countries. When you have linked to your EORI number all the VAT numbers that you use in the EU territory, you can use the EORI number in customs declarations throughout the EU territory.

Read the detailed instructions for providing the EORI number on the webpage: How to submit an import declaration.

Read more about applying for an EORI number.

In addition to the trader details, the customs declaration must always contain the transaction value; customs duties will usually be levied based on this value. The customs value is usually the transaction value of the goods, i.e. the price actually paid for the goods.

To determine the customs value of the goods, the declarant (usually the importer) must enter the invoice in the customs declaration and present it to Customs when necessary. For an invoice to be used, the following conditions must be met:

• The goods of the invoice were sold for export to the customs territory of the EU.
• Except in the case of an occasional import, the importer must have legal capacity in the customs territory of the EU.

Trader details in chain transactions

The sale of goods may involve chaining, i.e. the goods may have been sold several times before they were imported to the EU. If the goods were sold more than once, the customs value is determined based on the last sale that took place before the goods were imported to the customs territory of the EU. Even in a chain transaction, you must be able to present an invoice based on which the customs value is determined.

The declarant lodging the customs declaration (usually the same as the importer) must be able to fulfil the importer’s responsibilities that is, to present the goods and the invoice, among other things. Therefore, when you enter the trader details in the customs declaration based on a chain transaction, please note the following:

• temporal allocation, i.e. whether the sales in the chain transaction took place before or after the arrival of the goods in the EU territory
• the physical location of the goods, i.e. were the goods, for example, sent directly to the consignee
• what was agreed in the trade agreement between the companies about submitting customs declarations
• which transaction value can be used, i.e., which invoice is available to the declarant

Example: A company (A) outside the EU first sells the products to a company (B) located in the EU. After this, the company (B) sells them onward to another company (C) in the EU. The declaration in question is based on a chain transaction where, depending on the situation, the declarant (importer) can be either company B or company C:

a) In the trade agreement, the agreed upon importer of the goods is company B. The goods first arrive in the possession of company B, after which they are delivered to company C. In this case, the importer can be company B.

b) In the trade agreement, the agreed upon importer of the goods is company C. The goods are delivered directly to company C. Furthermore, the trade between the companies B and C took place before the goods were imported to the EU. In this case, the importer can be company C.

Read more about providing value information in a customs declaration and on the customs value.

If the importer is established outside the EU

The importer can be established outside the EU, but in that case, the company must find out if the importer needs to register in Finland. The importer must find out, which authorities they must register with. The need for registration can be affected e.g. by the customs procedure and the goods to be imported.

For example, the import of certain products requires a registration with the Finnish Food Authority. Read more on the Finnish Food Authority’s website.

Concerning VAT, enquire about the registration requirement from the Tax Administration. If the importer is established outside the EU and the company is not registered for VAT in Finland, Customs will levy the VAT on import with a customs invoice. In this case, read about the refund of VAT to foreign entrepreneurs established outside the EU on the Tax Administration’s webpage:

• Refund of VAT to foreign businesses established outside the EU (vero.fi)
• Self-employed individual operating in another country – How to request a refund from Finland (vero.fi).

If the importer is established in another EU country

The importer can be established in another EU country and declare himself as an importer. The importer must find out, whether registration with some authority in Finland is required for importing goods directly to Finland.

For example concerning VAT, the registration requirement must be enquired from the Tax Administration. VAT on import is levied in different ways, depending on whether or not the importer is registered for VAT in Finland:

• If the importer is not registered for VAT in Finland, Customs levies the VAT on import with a customs invoice.
  • Read more about the VAT refund (vero.fi).
• If the importer is registered for VAT in Finland, the importer declares the VAT on import to the Tax Administration.
  • If the importer has an EORI number granted in another EU country and the importer is registered for VAT in Finland, enter the EORI number in the importer’s details of the customs declaration. In turn, enter the Finnish VAT number with the additional fiscal reference role code “FR1 – Importer”.
  • Enter on your own initiative the details of the goods import in the VAT declaration to the Tax Administration. Read more about how to declare the VAT on import (vero.fi).

Please note that if the company wishes to use, for example, its subsidiary that is registered in the VAT register in Finland as an importer of goods acquired for its business, the VAT on the importation cannot be deducted with the importer's VAT declaration to the Tax Administration. For more information on the right to deduct VAT on import, contact the Finnish tax Administration. Check the contact information and services of the Tax Administration (vero.fi).

If you act as an indirect representative, please note that you have more responsibilities than a direct representative has. An indirect representative has all the responsibilities of a declarant. If a representative is also the importer in the customs declaration, he is also responsible for the VAT.

If the indirect representative represents an exporter established outside the EU

If the exporter, i.e. the seller, is not established in the EU territory, he cannot be the declarant in the customs declaration. In that case, the exporter must use an indirect representative. The exporter of the goods can assign the representative to submit the customs declaration, e.g. when using the delivery term DDP (DDP (Delivered Duty Paid).

Please note the following concerning the responsibilities of the indirect representative:

• If the representative only has a power of attorney from the exporter, i.e. the seller of the goods, the representative must always be an indirect representative. The representative is the declarant in the customs declaration. The seller of the goods is the importer and the exporter in the customs declaration. The buyer of the goods or the consignee is entered under “buyer” in the customs declaration.
• If the representative wants to use the buyer of the goods as importer (e.g. a Finnish buyer of the goods), the representative must have a power of attorney from the importer. In the customs declaration, the declarant is the indirect representative and the importer is the buyer of the goods. The exporter is an exporter established outside the EU.
• If the representative does not have a power of attorney from the importer, rather he acts in his own name and the goods as well as the required information and documents are in his possession, then the representative carries all the responsibility. In that case, the representative enters himself as the declarant and importer in the customs declaration. However, the buyer of the goods or the consignee must be entered under “buyer” in the customs declaration.
  • Please note that if the goods are customs cleared for free circulation in the name and on behalf of the indirect representative, there is no right to deduct or be refunded VAT paid for the importation of the goods. For more information on the right to deduct or be refunded the VAT on import, contact the Finnish tax Administration. Check the contact information and services of the Tax Administration (vero.fi).

If the representative does not want to take on the importer’s responsibility, the representative must acquire a power of attorney regarding this from the importer (e.g. a Finnish buyer of the goods), who is established in the EU territory. With the power of attorney, the importer must take on the declarant’s responsibilities, in which case it is not a question of an indirect but of a direct representation. In that case, the representative can be entered as the declarant as well as importer in the importer’s customs declaration.

When the indirect representative has submitted a customs declaration for CBAM goods, the CBAM report can be submitted either by the indirect representative or by the importer.

If a form of representation other than indirect representation has been used in the customs declaration (e.g. direct representation under the guarantor’s responsibility), the importer must submit the CBAM report.

However, please note that an importer established outside the EU must always use an indirect representative to submit the CBAM report. This representative must be the same as the one in the import declaration.

Read more about the Carbon Border Adjustment Mechanism (CBAM).

With the additional fiscal reference role code, you can provide more information on the trader. The additional information can be e.g. the VAT number granted by Finland or some other EU country.

You can use the following codes:

• FR1 – Importer
  • Use the code when the trader is a company registered for VAT with the Finnish Tax Administration and it has an EORI number granted by some other EU country. Enter under “Parties” the EORI number granted by the other EU country, for example in the declarant’s or the importer’s details. In turn, enter the VAT number granted by the Finnish Tax Administration with the additional fiscal reference role code “FR1”.
• FR2 – Customer
  • Use the code when the requested procedure is ”42 – Release for free circulation and home use of goods exempt from VAT to another Member State” or ”63 – Re-importation with simultaneous release for free circulation and home use of goods which are the subject of a VAT-exempt supply to another Member State and, when applicable, an excise duty suspension.” If you import is subject to VAT in addition to this, read more Declaring excise products in import declarations. Examples of the use of the code “FR2”:
    • The importer of the goods is a trader registered in the Tax Administration’s VAT register, who has sold the imported goods as direct intra-Community trade from one company to another in the EU territory. The company, which has bought the goods as intra-Community trade and which receives them in the Member State of destination, must be registered in the VAT register of the Member State of destination.
      • Always enter the VAT number, which the Member State of destination has granted the buyer, with the additional fiscal reference role code “FR2 –Customer.”
      • If the company has a Finnish EORI number, enter the Finnish EORI number in the importer details of the customs declaration. Based on this, the company is identified as having a Finnish VAT number granted by the Tax Administration.
      • However, if the importer has an EORI number granted in another EU country that should be provided as the company’s identifier in the customs declaration, enter with the code “FR1 – Importer” the Finnish VAT number granted by the Tax Administration.
    • The importer of the goods is a trader registered in the Tax Administration’s VAT register, who delivers the goods for use by the company in another EU country, where the transport ends. The company is also registered for VAT in this other EU country.
      • Always enter the VAT number, which was granted by the other EU country where the transport ends, with the additional fiscal reference role code “FR2 –Customer.”
      • If the company has a Finnish EORI number, enter the Finnish EORI number in the importer details of the customs declaration. Based on this, the company is identified as having a Finnish VAT number granted by the Tax Administration.
      • However, if the importer has an EORI number granted in another EU country that should be provided as the company’s identifier in the customs declaration, enter with the code “FR1 – Importer” the Finnish VAT number granted by the Tax Administration.
    • Read more on how to declare when the transport of the imported goods ends in another Member State (in Finnish).
  • FR5 – Vendor (the VAT special scheme for import, IOSS)
    • When an IOSS consignment is in question and you have an IOSS number, enter the vendors IOSS number with the code FR5.

The fiscal additional reference code FR3 cannot be used, since there is no tax representative in Finland. Neither can the fiscal reference code “FR4 – Holder of the deferred payment authorisation” or “FR7 – Taxable person or of the person liable for payment of VAT” be used in the import declaration.

Union Customs Code (Regulation (EU) No 952/2013 of the European Parliament and of the Council), Articles 5, 9, 61, 74, 77, 250, 163 and 170