If you are a Finnish citizen, Finland keeps you as a general taxpayer for the year you move and three more years, unless you show that your substantial ties to Finland are cut. That rule decides when you have really left. The good news for leavers: Finland's Income Tax Act has no departure tax on an individual's unrealised gains.
Who is resident in Finland
Under section 11 of the Income Tax Act (tuloverolaki, TVL) you are resident in Finland if you have your actual home and abode there, or if you stay in Finland continuously for more than six months. A temporary absence does not break the continuity of a stay.
The three-year rule for Finnish citizens
The same section adds a rule for citizens. A Finnish citizen is treated as resident, even without a continuous stay of more than six months, until three years have passed from the end of the year of departure, unless they show that they had no substantial ties to Finland in the tax year. After that period a Finnish citizen is not considered resident unless otherwise shown. The rule is in the current consolidated text of the act.
Verohallinto, the Finnish Tax Administration, puts it in practical terms: a Finnish citizen who moves abroad is as a starting point a general (unlimited) taxpayer in Finland for the year of the move and the three following years. If you move in 2027, that runs to the end of 2030.
Substantial ties: what keeps you in
According to Verohallinto's guidance, during the first three years substantial ties are generally deemed to exist if any one of these applies:
- a dwelling remains in Finland;
- your spouse remains in Finland;
- real estate other than a summer cottage remains;
- you belong to Finland's residence-based social security;
- you carry on business in Finland;
- you work in Finland.
The guidance adds four points that decide most real cases:
- The move must be permanent. That is the key condition for cutting substantial ties.
- Letting out your home is not enough. Renting out the former home generally does not cut the tie.
- A cottage is fine. A summer cottage with its plot, or an investment flat that has not been the family home and is not suitable as one, does not by itself form a substantial tie.
- Moving assets around does not help. Substantial ties cannot be avoided by moving all your assets into your spouse's ownership or into your own company.
When limited liability starts
The timing depends on when the ties are cut:
- At the moment of moving. A citizen who moves mid-year is treated, on request, as a limited taxpayer from the moment of the move if they show that the substantial ties were cut at that moment (Supreme Administrative Court, KHO 1981 taltio 3184).
- Later, within the three years. If the ties are cut after the move but before the three years have run, you can claim limited liability from the start of the following year. Apart from the moment of moving, it cannot start mid-year.
Once your ties have been found cut and you are a limited taxpayer, you become a general taxpayer again only if your actual home moves back to Finland or you stay in Finland for more than six months.
No exit tax for individuals in the Income Tax Act
The only exit-tax section in the consolidated Income Tax Act is section 30 b, headed "Yhteisön maastapoistumisverotus": it applies to entities (yhteisö), not to individuals. No departure tax on an individual's unrealised gains was found in tuloverolaki. This page relies on the Income Tax Act; it does not survey every other Finnish statute.
The question has been studied. In February 2020 the Ministry of Finance published report 2020:9 on a departure tax for individuals. Its tax department found that such a tax would face so many problems that, instead of immediate legislation, it would be better to monitor how the need for regulation and the international situation develop. The reasons given: it would complicate the tax system, enforcement and information gathering would be hard, it would hit a small wealthy group, and it could harm competitiveness and migration. The report is a ministry study, not law.
The CFC act
Finland also has a separate act on the taxation of shareholders in controlled foreign companies (laki ulkomaisten väliyhteisöjen osakkaiden verotuksesta). Under its section 2 the rules apply where you, with related parties, hold at least 25 percent of the votes, capital or profit rights, and the entity's effective tax level in its jurisdiction is below 3/5 of the tax level of a Finnish resident company. How Finland classifies a US LLC is not settled in the sources checked for this page, so check this point for the years you are still a general taxpayer.
Telling DVV you are leaving
Moves must be notified to the Digital and Population Data Services Agency (Digi- ja väestötietovirasto, DVV) at the earliest one month before and at the latest one week after the moving date. A notice of emigration must be made in writing or electronically, and it must give your name, personal identity code, moving date, address abroad, the purpose of the move and the length of your stay abroad.
If you move abroad for longer than one year you no longer have a municipality of residence (kotikunta) in Finland, unless your life circumstances tie you more closely to Finland than to your new country. That is a test under the Municipality of Residence Act. Your tax position is decided separately, under the Income Tax Act rules above.
The right sequence
What goes wrong if you skip a step
- You keep the former home, even rented out: the tie stays.
- Your spouse stays in Finland: that alone is a substantial tie.
- You keep working or doing business in Finland: same result.
- You move assets into your spouse's name or your own company: the tie is not cut.
- You cut the last tie in, say, June: limited liability starts only on 1 January of the next year.
The US side of the LLC is explained in how the LLC is taxed. Neighbouring countries: Norway, Sweden, Denmark.
Sources
Checked 26 October 2026.
- Tuloverolaki (1535/1992), sections 11 and 30 b: finlex.fi
- Laki ulkomaisten väliyhteisöjen osakkaiden verotuksesta (1217/1994), section 2: finlex.fi
- Kotikuntalaki (201/1994), sections 5 and 7 a: finlex.fi
- Verohallinto, "Yleinen ja rajoitettu verovelvollisuus sekä verosopimuksen mukainen asuminen", VH/184/00.01.00/2025 of 29 January 2025: vero.fi
- Verohallinto, "Suomesta ulkomaille": vero.fi
- Valtiovarainministeriön julkaisuja 2020:9, "Selvitys luonnollisten henkilöiden maastapoistumisverosta": valtioneuvosto.fi
Your own case
This page is general information, not advice on your case. Your ties, your timing and your claim for limited liability are checked in the consultation, held in English.
Form your LLC