Finland: Ruling on life insurance saving agreement

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Finland: Ruling on life insurance saving agreement

The Finnish Central Tax Board (CTB) has given a preliminary ruling (KVL 34/2011) regarding taxation in connection with transfers of investments in life insurance saving agreement and capitalisation agreement where the taxpayer has the right to decide on which assets the policy funds are invested in.

Life insurance saving agreement refers to a life insurance policy that combines life insurance with the features of a savings and investment account. The gains from the investments accumulate tax-deferred. Capitalisation redemption agreement refers to an investment linked insurance with no specific insured. Like life insurance saving agreement, also in capital redemption agreement gains from investments accumulate tax-deferred.

In the matter before the CTB the taxpayer was planning to conclude either a life insurance saving agreement or a capitalisation agreement with an insurance company. In said agreements, the premium paid to the insurance company could be invested in different types of assets. The insurance company was the owner of the assets and also had the right to assign the assets and invest the received funds in other assets. The terms and conditions, however, stipulated additionally that it was possible to grant the policyholder an independent right to decide on the transfers and investments during the term of the policy.

The assignment of investments linked to the life insurance or the capitalisation agreement by the insurance company during the term of the policy was not considered to be a taxable transfer in taxation of the policyholder. According to the CTB the policyholder did not receive taxable income from said transfers nor did any tax-deductable loss arise although he or she would be entitled to decide on the investments independently.

Janne Juusela (janne.juusela@borenius.com)

Borenius – Taxand

Tel: +358 9 615 333

Website: www.borenius.com

more across site & shared bottom lb ros

More from across our site

Clients care more about considered counsel than rapid media-friendly soundbites, says Matthew Gilleard, associate director at Infinite
It was also a memorable night for Galicia, KPMG, Skadden and Pinheiro Neto, all of which scooped major awards at a gala ceremony in New York
The former Deloitte UK CEO earned a 45% raise in a year when 1,000 staff reportedly lost their jobs – and the pay gap is only getting bigger
In a seminal development for big law, the 95-year-old firm is set to cease operations after a series of high-profile partner departures
UK Chancellor John Healey extended a VAT cut, suspended tariffs, increased a bank surcharge and vowed to increase funding for HMRC
Kristine Riisberg warned that TP decisions can determine top-up tax exposure under pillar two, while global consensus over the rules remains unsettled
Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable
Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption
Opening doors for existing talent within Baker McKenzie and a desire for enhanced legal capabilities informed Ricardo Perera’s switch from KPMG
Boaz Goren’s move to the upstart PE-backed firm takes the number of senior UK tax professionals who have left EY this year to 13
Gift this article