Our statements on measures taken by the government and other authorities
Lausunto Helsingin asumisen ja maankäytön ohjelmaluonnoksesta
Asuntotarjonnan kasvattaminen on ainut kestävä tie kohtuullistaa kaikkien Helsingin nykyisten sekä tulevien asukkaiden asumiskustannusten kehitystä. Esitämme, että Helsinki nostaa vuosittain valmistuvien uusien asuntojen tavoitteen 7000 asunnosta vähintään 10 000 asuntoon. Esitämme myös joukon suosituksia ja muutoksia AM-ohjelman luonnokseen, jotka
tukevat kunnianhimoisen tavoitteen saavuttamista.
Government proposal for the Parliament regarding charging capabilities and charging points of electric vehicles and the automation and control systems in buildings
The Finnish Landlord Association wants to emphasize the importance of reaching climate objectives. In our opinion, the requirements set in the EBPD directive are adequate for charging points needs. There are, however, other means to significantly reduce traffic emissions. In addition to electrification, traffic in city centers should be reduced. The current proposal would lead to considerable expenses for property owners with no guarantees of the efficiency of vehicle fleet electrification measures.
In our opinion, the proposal for legislation should be adjusted to comply with the minimum requirements of the EBPD directive. For instance, if the price of electric cars goes down in the near future, market demand will result in the creation of more charging points. In addition, government should continue to provide economic support for projects related to adding charging points to appropriate locations. Also, the proposal suggests that a tenant has the right to demand a charging point if the capability is there. This is problematic for housing companies since there is no statement in the proposal regarding the ownership of the charging points and their procurement. This brings confusion for housing companies and for landlords and tenants.
Statement on the draft report by the working group on sharing economy, March 22nd, 2019
The Finnish Landlord Association shares the working group’s opinion
on how sharing economy can create new business and a
working culture where availability of services, freedom of choice, social
aspects, and efficient utilization of resources are emphasized.
However, in a worst-case scenario, the benefits of sharing economy may be left unrealized
due to an imperfect regulatory environment.
For short-term accommodation, the most important current issues are the
drawing of boundaries between a professional and a non-professional operation
and the inconsistency in interpretations by various authorities. Housing
needs are changing and there must be room for new services to
develop in the market. There is a clear need for short-term leases and home-like
accommodation services. Any regulations should not aim to
protect traditional businesses. Instead, the need for any new or
additional regulations must be thoroughly assessed.
Regulatory burden should be reduced rather than increased.
Statement on government proposal to Parliament for the 2019 state budget, October 8th, 2018
The Finnish Landlord Association has issued a statement regarding
the state budget proposal for 2019. The Finnish Landlord Association
wants to draw the attention of the Environment Committee to four essential
housing related budget themes:
1. Housing production subsidies are currently an ineffective proposition
2. Investing in traffic efficiently creates housing supply
3. The housing benefit system must be individually aligned
4. Taxation of rental income is ultimately paid by tenants
Statement on the working group report on assessment of tax treatment of different forms of investment, June 15th, 2018
The Finnish Landlord Association has issued a statement regarding
the report by a working group focused on the neutrality of
different forms of investment. We are still far from neutral treatment of various
forms of investment. The working group mainly focused on creating
a Finnish investment account model. Neutrality would require that
various forms of investment, not only stock investments, are taken into account
in the development of the investment savings account. Neutral taxation
allows free investment of capital in the most efficient way.
With the obstacles related to electronic exchange systems
removed with the upcoming electronic housing company register (ASREK), there is no basis for excluding shares in a housing company as an option for an investment savings account.
Statement on the government proposal draft regarding the Act on the Residential and Commercial Property Information System, May 4th, 2018
The Finnish Landlord Association considers the ASREK project a necessary
and welcome development. The need for a register for shares in a housing company and the digitalization of related
processes has existed for a long time. The ASREK project speeds up
the general digitalization of the real estate industry and
creates prerequisites for companies to digitalize their
processes and services. An electronic register for shares in a
housing company would allow shares to be included in the
planned investment savings account, making taxation of
different forms of investment more neutral.
Statement on the proposal by the police authorities regarding the Personal Data Act, January 21st, 2018
The Finnish Landlord Association, Finnish Tenants, and RAKLI have
issued a statement regarding the Personal Data Act of the police. We
suggest an amendment which would allow the police to hand
data over to landlords and to housing companies for ending a lease
agreement or for taking possession of the apartment. The right to the
data would apply to situations where a police report has been
made because of disturbances or violations of a building’s ordinance.
The data should include the following: the number and dates of
the police reports, the number and dates of police visits to the
apartment, and whether these visits were made due to disturbances
or violations of the building’s ordinance.
Expert statement: Audit Committee study ‘Areas for development in housing policy’, November 15th, 2017
In the opinion of the Finnish Landlord Association, the study is well
prepared. It includes a number of good suggestions for developing housing
policy. The Finnish Landlord Association thinks that Finland is on the right path
regarding its housing policies. Traffic initiatives and their significance to housing
production is better understood and the supportive measures have now
begun to shift from production to demand. This is the
correct direction for our housing policy.
Statement on government proposal for amending the housing benefit act, October 9th, 2017
The Finnish Landlord Association has a critical opinion regarding
the government proposal to add a norm for shared housing in the housing benefit
system. This is a bad decision that steers people away from shared housing that
helps decrease housing benefit costs. Students are already beneficiaries
of the general housing allowance, which further exacerbates the issue. Most
shared housing residents are students, and the current concept of
a household unit is already affecting the popularity of shared housing negatively.
Expert statement: government’s 2018 state budget proposal, September 21st, 2017
The Finnish Landlord Association would prefer the government to
acknowledge the current housing market more realistically. As
the current economic cycle favors construction, it is not smart to
increase ARA’s production. The mounting taxation of rental income does
not help the market. Taxes should be cut in order to slow down
the price hikes and to increase supply.
Statement on changing the real estate tax, September 12th, 2017
It is the opinion of the Finnish Landlord Association that the government proposal to increase real estate tax in addition to prior resolutions is a step in the wrong direction. Increased living costs have eroded purchasing power, and continuously increasing maintenance and renovation costs further affect the cost of living. Raising the real estate tax is directly reflected in maintenance charges and rent prices, undoubtedly burdening residents further.
Statement on the cooperative model for social residency, September 8th, 2017
The Finnish Landlord Association supports this proposal. One of the
most important goals of the proposal is to simplify the prerequisites
for arranging housing. The current production subsidy system does
not meet today’s demands and new development models are needed.
The production subsidy system should become more supportive towards special housing services.
The production of regular rental apartments should be based on market conditions, and the potential of private
landlords should be utilized better.
Statement on sharing economy, August 18th, 2017
The Finnish Landlord Association sees the sharing economy as a major global trend
which will grow stronger regardless of whether it is actively promoted
or obstructed or stalled. Trying to stop the sharing
economy from flourishing is not smart or even possible with national
legislation. Instead, we feel the primary goal should be to adapt
the legislation and/or its interpretation to allow for new business models
to develop. The legislative environment should set a solid yet
extensive framework for various forms of operation. Operations should not be
forced into a grey area and the operators should not be made to
feel insecure about the legitimacy of their operation or confused
about the rules.
Comment on the guidelines for the development of the interest rate subsidy model for long-term loans, April 7th, 2017
In short: it is the opinion of the Finnish Landlord Association that
housing subsidies should gradually be shifted from production subsidies to demand
subsidies. Housing subsidies should be directed to those who need them
most, in the most efficient and fair manner. At the moment,
there are approximately 200 municipalities in Finland where ARA rents are higher than
free market rents. The subsidy system does not function well if
market rents are lower than cost rents.
Statement on new construction via demolition March 30th, 2017
In brief: the Finnish Landlord Association issued a statement concerning new construction
via demolition that housing companies pursue. The association sees
plenty of positives in the bill but insists some economic incentives
should be added for housing companies. New construction via demolition
is an option, for instance, during a major plumbing renovation. However, new construction
should always be financially worthwhile. Cities especially aim to
implement this type of construction. The association feels this
would efficiently help compact the urban structure and provide urban
infill. The association’s managing director Mia Koro-Kanerva was
a member of the working group that prepared the bill.
Statement on the amendment of the act on real estate tax, September 29th, 2016
In brief: the Finnish Landlord Association is against the planned
tax increase. The increase will be directly reflected in living costs and
rent prices. As the act on real estate tax is amended, the minimum
obligation for real estate taxation should be removed so that
municipalities have the authority to decide on it themselves.
on amending the Act on Interest Subsidy for Rental Housing Loans and
Right of Occupancy Housing Loans, the Act on State-subsidized
Housing Loans and the Act on Subsidies for Improving the Housing Conditions of Special Groups, October 11th, 2016
In brief: the Finnish Landlord Association has a critical opinion on
subsidized production of rental apartments and sees that it skews
the housing market. Allocating public subsidies to those who most need
them is best secured by a demand-based system.
Expert statement on the 2017 state budget for the Parliament’s Housing and Environment Sub-committee, October 17th, 2016
In brief: the statement highlights the positive aspects and targets
for development. The land use, housing and transport (MAL)
agreements between major cities and the state have had a
positive effect. They should be developed further. The Finnish Landlord Association
also thinks that ARA’s role in implementing housing policy should be revised and clarified.
Statement for the Finnish Ministry of Social Affairs and Health regarding the inclusion of student housing allowance in general housing allowance, October 19th, 2016
In brief: the Finnish Landlord Association supports the simplification and
equalization of housing subsidy systems. From this point of view, the inclusion
of the student housing allowance in the general housing allowance is a smart move
encouraged by the association. The association also encourages further development of the support systems.
Statement on amending the act on inheritance and gift tax, August 22nd, 2016
In brief: the Finnish Landlord Association supports the reduction of
inheritance and gift taxes. This helps keep capital in the rental market.
Taxation should also help keep as many rental apartments in the market
as possible following succession. In the long run, the Finnish Landlord
Association supports the removal of the inheritance tax and the shift to
the model used in Sweden which focuses on the taxation of capital gains.
Statement on the government proposal to amend the Act on Subsidies for Improving the Housing Conditions of Special Groups
Statement to the Housing Finance and Development Centre of Finland (ARA) regarding the new model for subsidized production of rental apartments
Statement to the Financial Supervisory Authority regarding the regulations and instructions on the calculation of Loan to Value Ratio
Statement to the Ministry of the Environment regarding the report on the effect of housing subsidy systems and tax systems
Statement to the Housing and Environment Sub-committee of the Finance Committee regarding the 2015 state budget