Application for refund of Finnish withholding tax on dividends, interest and royalties (non-natural persons, such as corporate entities) – instructions for filling in Forms 6163e and 6167e (enclosure)

Using the tax-at-source card in the year of payment

A corporate entity can apply for a tax-at-source card from the Tax Administration by filing Form 6211e, electronically in MyTax, or by using the Ilmoitin.fi service. The tax-at-source card must be presented to the payer before the income is paid. This allows the payer to withhold the correct amount of tax at source on the income when it is paid.

The corporate entity can also use the tax-at-source card to request their account operator to adjust the withheld tax-at-source in the year of the payment (“quick refund”), if too much tax has been withheld on dividends, interest, or royalties. This way, the entity does not need to request a tax-at-source refund from the Tax Administration.

If too much tax has been withheld at source, the taxpayer can use these instructions and Form 6163e to request a refund of the tax-at-source from the Tax Administration after the payment year. Do not request a tax-at-source card for the purposes of making an application for a tax-at-source refund.  

General instructions for filling in Forms 6163e and 6167e

These instructions concern non-resident foreign corporate entities’ application for refund of tax-at-source (Form 6163e) and its enclosure (Form 6167e). Detailed instructions for filling in Form 6167e are found at the end of this document. Submit Form 6167e together with Form 6163e when you are requesting a refund for more than one dividend batch.

You can download the forms on our Forms page.

Before you fill in the application, read our detailed guidance on the payments of dividends, interest and royalties to nonresidents.

If you complete the application form by computer, make sure that all the information has been saved correctly and in the correct fields before printing out the form. Make sure that the formatting of the text has not changed during printing.

Form 6163e is only for foreign corporate entities requesting a refund of Finnish tax withheld at source on dividend, interest or royalty income paid by a Finnish company. You must fill in a separate refund application for each type of income. In other words, an application for refund of dividend income, for example, can contain only dividend income but it may contain more than one dividend batch or dividend batches paid in different accounting periods. In these cases, use Form 6167e (enclosure).

You can also request a refund of tax-at-source electronically. You can use these same instructions when filling in an electronic application. Electronic applications may be submitted by the foreign corporate entity or by an agent or a representative acting on their behalf.

Make an individual electronic application in MyTax. After logging in, select Report or request information in a limited scope. Bulk submissions can be submitted to the Tax Administration through the Ilmoitin.fi service. A bulk submission consists of multiple applications by multiple applicants, submitted in a single XML file.

Read more about electronic filing of refund applications for tax withheld at source.

Form 6163e cannot be used if:

• The applicant is a natural person. Request refund of a natural person’s tax withheld at source on Form 6164e. However, Form 6167e can also be used as an enclosure to Form 6164e.
• The applicant has a permanent establishment in Finland. If the applicant is considered to have a permanent establishment in Finland and the income is attributable to that permanent establishment, the income and the tax withheld at source must be reported on the income tax return (Form 6U). More information on permanent establishments.

• The applicant’s place of effective management is in Finland. If the foreign corporate entity’s place of effective management is in Finland, it is considered a resident taxpayer in Finland and its income must be reported on the income tax return (Form 6B). Read more about when the place of effective management is considered to be located in Finland.

• The Tax Administration’s forms cannot be used by Finnish corporate entities applying for a refund of tax-at-source from abroad. Refunds must always be requested from the country that has withheld the tax-at-source.

The Tax Administration will pay out the tax-at-source refund if the refundable amount is at least €10. The application for refund of tax-at-source must be delivered to the Tax Administration within three years from the end of the calendar year in which the tax was withheld.

Completing and submitting the application

Select the language of the form. You will receive the decision and any requests for further information in the language you select here:

• Application form in Finnish
• Application form in Swedish
• Application form in English

Enter all amounts in euros. The Tax Administration’s decision also states the refundable amount in euros.

Fill in the form carefully and add any required enclosures in order the application can be processed without delay. Each field on the form is reserved for specific information. Please fill in only the required details specified for each field. For example, fill in the street address, postal code and post office in the separate fields provided on the form. Some entries can be made by attaching a sticker on the form (such as addresses or bank account details). If you use a sticker, it must stay inside the frame of the appropriate field on the form. However, if you have a sticker indicating the applicant’s official name, you can attach it on the form even if it is larger than the appropriate field.

When your application form arrives at the Tax Administration, it undergoes optical character recognition during scanning and is then saved as a computer file. For this reason, it is important that the QR code on the form is not hidden by a stamp, by a handwritten text or other markings.

If you submit multiple applications at once, place the application form (6163e) on the top and all the related enclosures underneath it. Do this with each new application and its enclosures. This way, the enclosures will be connected to the correct application when the applications are digitised.

You can print out the form on one page or on two pages. If you prefer, you can fill it in by hand.

Send the completed application form to the address stated at the top of the form. You can also deliver it to any office of the Finnish Tax Administration, such as the following address: Finnish Tax Administration, Registry, Vääksyntie 4, 00510 Helsinki.

Remember the enclosures and the basis for the application

Enclose the following documents with the application:

• A certificate of fiscal residence for the dividend payment years that the application concerns or, in exceptional cases, another official certificate of registration (see Certificate of residence).
• A power of attorney issued by the applicant if the applicant has an agent or a representative acting on its behalf. If the applicant wants the refund to be paid into the agent’s account, the power of attorney must state that it also entitles the agent to receive the refund. If the applicant is represented by more than one agent, all agents’ powers of attorney must be enclosed with the application.
• Verification that the persons signing the application or the power of attorney are authorised to sign for the applicant. Make sure the signers’ names in print are written clearly and are easy to read.
• A receipt or voucher for dividends paid, made out to the applicant. The voucher must indicate that it concerns a dividend payment. A summary receipt is also acceptable, as long as it is issued or verified by an account operator, a bank or some other intermediary. The Tax Administration may ask the applicant to present a full audit trail from the first payer to the final beneficiary.
• A separate account of the chain of intermediaries, if the chain of intermediaries is too long to be entered in the field reserved for it (field 5.18) or if different dividend batches have different chains of intermediaries. Give the names of all the intermediary banks and account operators that have handled the transfer of the dividend payment from the payer to the final beneficiary, i.e. the applicant (see Intermediary banks).
• A list of sub-funds if the applicant is the main fund or a sub-fund of an umbrella fund (see Umbrella funds).
• Affirmation given by a US pension fund (Form 6160e), if the applicant is a US pension fund and the application is based on the tax treaty between Finland and the United States of America.

If the basis for the application is that the applicant is comparable to a Finnish tax-exempt entity, also enclose:

• Grounds for why the applicant is comparable to a tax-exempt Finnish entity. The grounds are a mandatory part of the application.
  • If the basis for the application is that the applicant is comparable to a Finnish investment fund or special investment fund, specify the applicant’s legal form and operational features (see Applicant comparable to a Finnish investment fund).
  •  If the basis for the application is that dividends paid by a publicly listed company to another publicly listed company are tax-exempt, specify the stock exchange where the applicant was listed and publicly traded on the date of dividend payment. Also state the stock or ticker symbol and the ISIN code.
  • If the basis is that the applicant is comparable to a Finnish pension institution, see more detailed instructions in the section Pension institutions and life insurance companies.
• A certificate or other documentation issued by the tax authority of the applicant’s country of residence, stating that the country of residence cannot credit the Finnish tax-at-source in full.  You can use Form 6161e (Certificate of tax treatment concerning dividends).

Note: Even if the corporate entity has been previously issued a tax-at-source card or granted a refund, grounds must still be enclosed with the application. If you refer to a previous decision in the grounds, also affirm that the applicant’s circumstances have not changed.

How to complete form 6163e

1 Applicant (beneficial owner)

Enter the applicant’s details here.

1.1 Applicant’s official name

Enter the name of the applicant in its official form, i.e. spell it in the same way as it is spelled in the applicant’s certificate of fiscal residence or other official document. If the applicant’s name has changed, report the change in a separate attachment. Indicate in the attachment when the change of name took effect.

1.2–1.3 Accounting period for interest calculation

Fill in the start and end dates of the accounting period when the income was paid to the applicant. If you are filing a refund application for a tax-at-source on dividends paid during multiple accounting periods, enter only one accounting period and the dividend batches paid during that period on the form. Report the other accounting periods and their dividend details in an enclosure (Form 6167e). Enclose a separate Form 6167e for each accounting period.

Example 2: The applicant’s accounting period starts on 1 April and ends on 31 March. The applicant was paid dividends on 29 March 2023. Fill in the accounting period 1 April 2022 – 31 March 2023.

Example 3: The applicant has two accounting periods ending during the same calendar year: 1 April 2022 – 31 March 2023 and 1 April 2023 – 31 December 2023. The applicant was paid dividends on 15 March 2023 and 2 May 2023. Report the accounting periods separately. Report the accounting period 1 April 2022 – 31 March 2023 on Form 6163e, filling in the details on the dividends paid on 15 March 2023 in fields 5.9–5.15. Report the accounting period 1 April 2023 – 31 December 2023 on Form 6167e (enclosure), filling in the details on the dividends paid on 2 May 2023.

1.4–1.6 Postal address

Fill in the postal address, postal code and city in the appropriate fields. If the applicant’s postal address is not in its country of tax residence, enter the country of postal address in field 1.6.

If the applicant does not have an agent (see section 2), the Tax Administration will send the decision and any requests for further information to the address indicated here.

1.9–1.10 Country of residence

Enter the country code of the applicant’s country of residence. Please note that Finland (FI) cannot be a non-resident taxpayer’s country of residence. Enter the country code in accordance with the ISO 3166 standard (www.iso.org). You can check the country code on the page Tax treaties. Note, however, that only the countries that have a tax treaty with Finland are listed on the page.

1.11–1.13 Tax identification number in the country of residence

The tax identification number (TIN) issued by the applicant’s country of residence is mandatory information. If no TIN has been issued for the applicant, enclose a free-form account explaining this and fill in some other registration number issued by the applicant’s country of residence in field 1.12. Do not enter the TIN of a fund management company or other such related entity.

Leave field 1.13 blank if the applicant does not have a Finnish Business ID.

1.14–1.15 Legal form

Tick the appropriate box in 1.14 to indicate the applicant’s legal form. Enter the applicant’s entity type in the country of residence in field 1.15 and add the applicant’s more specific legal form, if possible. If none of the options available is correct, tick “Other”. In this case, describe the applicant’s legal form in field 1.15 and, if needed, on a separate enclosure.

Example 4: The applicant is a limited liability company. Tick option 1 “Corporate entity” in field 1.14 and specify in 1.15 by adding the description “Limited liability company”.

Example 5: The applicant is a US investment trust. Tick option 7 “Trust”, or option 6 “Non-UCITS fund”. Specify in 1.15 by adding a description, such as “Delaware Statutory Trust”.

1.16–1.17 Information on listing on a stock exchange

A company is publicly listed if any of its shares, or series of shares, are listed on a stock exchange i.e. the company's shares are traded on a regulated and government-supervised marketplace. Tick the box in 1.16 as appropriate, depending on whether the applicant was a listed or a non-listed company at the time when the dividends were paid.

Enter the applicant’s ISIN code in field 1.17. Leave blank if the applicant has no ISIN code.

If the company is publicly listed, enclose a free-form account specifying the stock exchange where the applicant was listed and subject to public trading on the date of dividend payment.

1.18 Umbrella funds

If the applicant is part of an umbrella fund, indicate in this field whether it is the umbrella fund’s main fund or sub-fund. If the applicant is a sub-fund, fill in the main fund’s name and tax identification number.

Enclose a list of sub-funds and tick the box “List of sub-funds is enclosed” regardless of whether the applicant is the main fund or a sub-fund. The receipts or vouchers enclosed with the application must specify which sub-funds the dividends were paid to.

Leave this field blank if the applicant is not a part of an umbrella fund.

Read more below in section Further instructions for special circumstances – Umbrella funds.

1.19–1.21 Information on previous refunds

If the applicant has previously requested a refund for tax-at-source from the Tax Administration, tick “Yes” in field 1.19.

If the applicant has requested a refund from the payer for at least one of the items of income covered by the application during the year of payment (“quick refund”), tick “Yes” in field 1.20.

If the applicant has previously requested a refund from the Tax Administration for at least one item of income covered by the application, tick “Yes” in field 1.21.

If the Tax Administration has issued any decisions on the applicant’s previous applications, report the decision numbers in field 1.24.

1.22 Is the applicant treated as having a permanent establishment in Finland?

This form is primarily for non-resident foreign corporate entities that does not have a permanent establishment in Finland. If the applicant is treated as having a permanent establishment in Finland and the income is attributable to that permanent establishment, the income and the tax withheld at source must be reported on the income tax return (Form 6U). Read more about having a permanent establishment for purposes of income tax.

1.23 Basis for the refund of tax withheld at source

If the refund of the tax-at-source is based on the tax treaty between Finland and the applicant’s country of tax residence, tick “tax treaty between Finland and applicant’s country of residence”. It must be clearly stated in the applicant’s certificate of fiscal residence that the applicant is subject to tax in its country of residence within the meaning of the tax treaty between Finland and the applicant’s country of residence.

Tick the box “EU Law” if the applicant refers to the fundamental freedoms of the European Union, such as the free movement of capital and free right of establishment, and holds that it has been discriminated in taxation at source, or that it should be considered tax-exempt in accordance with Finnish national law. Also tick “EU law” if the applicant’s request is based on an EU directive. Give more detailed grounds for the refund of tax-at-source in an attachment to the application. Note that it is mandatory to provide grounds for the application in order that it is processed.

In other cases, tick “other reason”. Enclose a free-form account of why the tax-at-source should be refunded. An example of “other reason” is that the applicant is not entitled to tax treaty benefits and it cannot be considered tax-exempt under national or EU law, but it can be considered a corporate entity under Finnish law and therefore entitled to a 20% tax-at-source rate.

2 Information on the representative signing the application form

If the applicant wants the Tax Administration to send the decision and any requests for further information to the agent, enter the agent’s name, company and address here. If the applicant is represented by more than one agent, enter here the details of the agent that is to receive the decisions and information requests, even if the application is signed by another agent.

Also enclose a power of attorney issued for the agent, and verification that the person who signed the power of attorney is authorised to sign for the applicant. The right to sign can be verified by providing a copy of an extract from the trade register or the corporate entity's rules, for example. A notarised power of attorney is also accepted as verification. The power of attorney and the verification of the right to sign must also be attached to applications submitted electronically.

The representative’s identifier (field 2.2) makes it possible to distinguish the refund applications submitted by a certain agent from all other applications. It also makes it possible to examine the status of all the applications submitted by a certain agent or representative. The identifier may be, for example, a Finnish Business ID, a tax identification number (TIN) issued by a foreign country or an identifier issued by some other public authority.

3 Bank account number for the refund

This section is for the bank account where the refund will be paid.

In the case of payments made within the Single European Payment Area (SEPA), fill in the account holder’s name, the bank account number in IBAN format and the bank’s BIC code. Note that the country code for the IBAN bank account number and for the BIC code must be the same. For example, if the IBAN begins with the country code FI, the country code used in the BIC must also be FI.

In payments made outside the SEPA zone, enter a country-specific clearing code and the name and address of the receiving bank, as well as the account holder and the bank account number.

If needed, you can add a reference number of your choice in field 3.9. The Tax Administration will use the reference number when paying the refund. The Tax Administration can also use the reference number in any requests for additional information concerning this application. Use an individual reference number for each different application.

4 Information on the income

This section is for details on dividend, interest or royalty income. Tick the appropriate box in field 4.

If the application concerns taxes withheld at source on dividend income, move on to section 5.

If the application concerns taxes withheld at source on interest or royalty income, move on to section 6.

5 Dividends

5.1 Receipt of dividends

Tick the box as appropriate, indicating whether the dividends were paid to the applicant due to nominee-registered shares or the applicant’s direct shareholding. Move on to field 5.7.

Nominee-registered shares are in the name of the nominee registration custodian, not in that of the actual owner. The payer does not therefore necessarily know the actual owner of the shares. Foreign corporate entities’ Finnish shares are usually nominee-registered.

5.2–5.6 Information on the fund or partnership

An applicant requesting a refund of tax-at-source must be the party who is considered to be the taxpayer under Finnish national law. If the income was paid to a foreign flow-through corporate entity, the application must be submitted in the name of the said entity. If the flow-through corporate entity does not have a TIN, the application form must include another registration number for the applicant. Do not give the TIN of the flow-through corporate entity’s fund management company as the flow-through entity’s TIN.

Partnerships are usually not considered separate taxpayers. In these cases, the refund application must be filed in the name of the partner and the details on the partnership are reported in sections 5.2–5.6.

Leave sections 5.2–5.6 blank if the income has not been paid to a flow-through corporate entity or through a partnership.

For detailed instructions, see section Flow-through units.

5.7–5.9 Information on the payer

Enter the payer's name in the same form as it is in the receipt or bank statement related to the dividend payment.

If the payer is a publicly listed company, also fill in the ISIN code of the security in field 5.8. The ISIN code is needed to identify the payer.

If the payer is a non-listed company, fill in the payer’s Business ID, as well as its name, in field 5.7 (if Business ID is available). You can check the Business ID in the Business Information System (BIS).

5.10–5.14 Information on the dividend payment

Enter the dividend amount in euros. In the case of multiple dividend batches, complete Form 6167e and enclose it with the application. Note that you may enter information of one accounting period on one form. Fill in and enclose as many forms 6167e as you need. Please note that the dividend batch reported on the main form (Form 6163e) must not be re-entered in the enclosure (Form 6167e).

Report the date when the dividend income was paid in field 5.10.

Enter the number of shares in field 5.11, and enter the gross dividend amount, the tax withheld on dividend income and the amount you request to be refunded in fields 5.12–5.14.

Example 6: 35% of tax-at-source was withheld on the applicant's income. The tax-at-source amounted to €350. However, the payer adjusted the tax withheld at source during the year of payment and paid back 20% of the tax, i.e. €200, to the applicant. The applicant is now requesting that the Tax Administration should refund the remaining amount of tax (€150, i.e. 15% of the income). Enter €150 as the “amount of tax withheld” and €150 as the “amount requested as refund”. Also tick “Yes” in field 1.20.

5.15–5.17 Total amount requested as refund

These fields are for the sum total of all the dividend batches for which you are requesting a tax-at-source refund. Enter the total gross amount of all the dividend batches you have reported on Forms 6163e and 6167e, the total amount of tax withheld at source, and the total amount of tax you request to be refunded. If you are requesting a refund for only one dividend batch, enter the same values in fields 5.15–5.17 as in 5.12–5.14.

Example 7: The applicant entered the following information about dividends paid by company A in Form 6163e: gross amount €1,000, tax withheld at source €300 and tax requested to be refunded €150. The applicant also completed Form 6167e, entering the dividends paid by company B: gross amount €500, tax withheld €150 and tax requested to be refunded €75. In fields 5.15–5.17 of Form 6163e, the applicant enters the sum total of the dividends paid by companies A and B: total gross amount €1,500, total tax withheld at source €450 and total tax requested to be refunded €225.

Example 8: The applicant requests a refund for dividends paid by company C. The applicant enters the dividend details in fields 5.12–5.14 of Form 6163e: gross amount €1,000, tax withheld at source €300 and tax requested to be refunded €150. The applicant reports the same details in 5.15–5.17: gross amount €1,000, tax withheld at source €300 and tax requested to be refunded €150.

5.18 Intermediary banks

Give the names of all the intermediary banks that have handled the dividend payment to the beneficiary, i.e. the applicant. If different intermediary banks were involved between the dividend batches, enclose a separate account of the chains of intermediary banks per each dividend batch.

Example 9: Bank C transfers a dividend amount to the beneficiary, i.e. to the applicant. Bank C has received the amount from a foreign account operator, bank B. Bank B has received the amount from a Finnish account operator, bank A. Bank A paid the dividends on the payer company’s behalf. Enter the names of all intermediary banks in field 5.18. Fill in Bank A, Bank B and Bank C as intermediary banks.

5.19 Form 6167e (enclosure)

You must give detailed information on each dividend batch. If you are requesting a tax-at-source refund for multiple dividend batches, fill in and enclose Form 6167e. In order to speed up the refund application process, it is recommended to apply for a tax-at-source refund from multiple dividend batches on one single refund application.

See the separate instructions for filling in the enclosure at the end of this page. Note that all the dividend batches must be filed on Forms 6163e and 6167e. Do not use free-form enclosures.

6 Interest payments and royalties

If you have received interest or royalty income rather than dividend income, fill in this section. When filling in this section, follow the instructions for fields 5.7–5.14 as given for dividend income.

7 Stock lending and borrowing, and beneficial owner

Tick boxes 7.1–7.4 as appropriate, depending on the type of income and the applicant’s circumstances. Do not leave these fields blank, unless otherwise instructed.

Dividend income

If the applicant was the beneficial owner of the dividends mentioned in the application, tick “Yes” in field 7.1. If you tick “No”, enclose a free-form account explaining why the applicant is entitled to a tax-at-source refund. Fill in the field only if you are filing the application based on the tax treaty between Finland and the corporate entity’s country of tax residence.

Tick “Yes” in fields 7.2 and 7.3 if the refund application includes shares that have been part of a total return swap, a futures contract or other derivative contract, or if the shares were lent or were part of some other contractual obligation. If you ticked “Yes” in either 7.2 or 7.3, please enclose the agreement on the lending or contractual obligation as well as an extract from the applicant’s safekeeping/securities account or other clarification of the loan periods, covering 30 days before and after the dividend record date. Also provide an account explaining why the applicant is entitled to a refund despite the lending or contractual arrangement.

Tick “Yes” in field 7.4 if the applicant has an unlimited right to shares and their profits. If you answer “No”, please explain why the applicant should still receive a tax-at-source refund.

Read more about the concept of beneficial owner (detailed guidance Payments of dividends, interest and royalties to non-residents, chapter 2.1.2).

Interest payments or royalties

Tick “Yes” in field 7.1 if the applicant was the beneficial owner of the interest or royalties referred to in the application. If necessary, enclose an account of the grounds why the applicant regards itself as the beneficial owner of the interest specified in the application. Fields 7.2–7.4 can be left blank.

Certificate of fiscal residence

Enclose a certificate of fiscal residence issued to the applicant for the dividend payment years referred to in the application. In exceptional cases, the certificate of fiscal residence can be replaced with another official certificate of registration. A certificate of registration is accepted if the basis for the refund application is not a tax treaty but EU law or some other reason (field 1.23).

Power of attorney and the right to sign for the applicant

Tick the appropriate box if the applicant has authorised an agent to act as its representative. Enclose a power of attorney. In addition, enclose documentation – such as an extract from the trade register or articles of incorporation – verifying that the person who signed the application or the power of attorney has the right to sign for the applicant. Make sure the signers’ names in print are written clearly and are easy to read.

How to complete form 6167e (enclosure)

1 Applicant

1.1 Official name

Enter the name of the applicant. Make sure the name is in the same form as in the application (Form 6163e).

1.2 Tax identification number (TIN) in the country of residence

Enter the applicant’s TIN or other registration identifier in the country of residence. Enter the same identifier you used in the application (Form 6163e).

1.3–1.4 Accounting period

Fill in the applicant's accounting period during which the dividends were paid. Report only dividends that were paid during the accounting period in question. If your refund application concerns tax withheld at source on dividends paid during more than one accounting period, fill in the details of one accounting period on Form 6163e. Report the other accounting periods on Form 6167e, completing a separate form for each period. Fill in and enclose as many forms 6167e as you need.

Example 10: The applicant was paid dividends on 3 May 2021, 2 May 2022 and 2 May 2023. The applicant’s accounting period is the calendar year. The applicant completes Form 6163e, entering the details on the dividend batch paid on 3 May 2021. The accounting period reported by the applicant is 1 January 2021 – 31 December 2021. In addition, the applicant completes two Forms 6167e. One concerns the dividend batch paid on 2 May 2022. The accounting period is 1 January 2022 – 31 December 2022. The other concerns the dividend batch paid on 2 May 2023. The accounting period is 1 January 2023 – 31 December 2023.

2 Specification of the dividends

Fill in fields 5.7–5.14 following the instructions given for Form 6163e.

Further instructions for special circumstances

Applicant comparable to a Finnish investment fund

If the basis for the application for refund of tax-at-source is that the applicant should be found comparable to a Finnish tax-exempt investment fund or special investment fund, enclose a free-form account of it. Before writing the free-form account, see the Tax Administration’s detailed guidance on the taxation of investment funds and the provisions of section 20a of the Income Tax Act concerning the requirements for tax exemption of investment funds and special investment funds. 

The free-form account you give must include at least the following:

• The fund’s legal form in the country of residence (e.g. fonds commun de placement (FCP), Sondervermögen, värdepappersfond or Delaware Statutory Trust).
• The legal Act under which the fund is established and the rules under which the fund is established (e.g. a contractual agreement or company by-laws).
• State which government officials supervise the fund.
• If the fund is managed by a separate management company, state the name of the management company.
• If the fund's assets are held by a separate custodian, state the name of the custodian.
• Is the fund open-ended with variable capital or closed? If the fund is open-ended with variable capital, state how and how often a unit holder can redeem its shares. Also estimate the fund’s total capital.
• Give an account of whom the subscriptions are marketed to, and estimate how many direct unit holders the fund had in the year when the dividends were paid. Report separately the unit holders who own their shares through a nominee register.
• State whether the fund is obligated by law or fund rules to distribute the profits of the accounting period to its unit holders. Also state if the fund distributes dividends or has other actual profit distribution, and how often.

Umbrella funds

An umbrella fund is a fund that is divided into several sub-unit series or sub-funds but whose sub-funds are legally part of the main fund (“umbrella”). From the legal point of view, only one fund exists. Applications concerning umbrella funds are filed in the name of that sub-fund who is the recipient of the income and by using the information of that sub-fund.

For example, if the sub-fund is a separate taxpayer and it is granted a certificate of fiscal residence in its own name, usually it also has its own TIN that must be used in the application instead of the main fund’s TIN.

Pension institutions and life insurance companies

If the application is based on the applicant being compared to a Finnish pension institution or life insurance company offering investment-linked life insurance products, fill in the other details on Form 6163e but leave field 5.14 ("amount requested as refund”) blank. If the application concerns more than one dividend batch, also leave the corresponding field on Form 6167e (i.e. field 2.8 “amount requested as refund”) blank. Instead, enter the total refund requested for all the dividend batches, after deductions, in field 5.17 on Form 6163e.

Enclose a calculation of all the income items and the taxes withheld at source. Also give detailed information on the deductions and its grounds.

In addition, provide a detailed explanation of the applicant's legal form and operations. For detailed instructions, read the Tax Administration guidance: Taxation of dividends received by foreign entities offering statutory pension insurance (chapter 3.1).

Also read the Tax Administration’s news article about the Supreme Administrative Court’s decision on the matter.

Flow-through units

An applicant requesting a refund of tax-at-source must be the party who is considered to be the taxpayer under Finnish national law. The tax liability is defined according to Finland’s national law. Corporate entities are treated as separate taxpayers, whereas partnerships are accounting units and the partners are subject to the tax on the partnership’s income. In determining whether a foreign operator is comparable to a corresponding Finnish operator, the operator’s legal and operational characteristics are taken into consideration. Before submitting the refund application, make sure whether the income is received by a flow-through corporate entity unit or a partnership. The application must be filed in the name of the party who is considered the correct taxpayer.

According to Finnish national law, an investment fund, for example, is a corporate entity and therefore considered separate taxpayer. Accordingly, a foreign corporate entity comparable to a Finnish investment fund is also considered to a separate taxpayer and to the party that can apply for a refund of tax withheld at source.

If the income is paid from Finland to a flow-through corporate entity, the application must be submitted in the name of the flow-through corporate entity. Even if the dividend income has been paid through a flow-through fund to the final beneficiary, the refund must be requested by the fund and not the final beneficiary.

If a flow-through corporate entity applies for a refund on behalf of its unit holders based on a tax treaty, enclose an account of these unit holders and the income amounts paid to them. Also enclose a statement explaining why the tax treaty can be applied to the unit holders’ income. Also verify each unit holder’s place of tax residence by enclosing a certificate of fiscal residence issued by their country of residence.

Example 11: Dividend is paid from Finland to an Austrian flow-through fund that has two Austrian unit holders. The unit holders request that the tax treaty between Finland and Austria should be applied to the income. The application is submitted in the name of the fund, and the Austrian unit holders’ certificates of residence are enclosed. A free-form account explaining why the tax treaty can be applied to the unit holders is also enclosed.

According to Finnish national law, a partnership is not a separate taxpayer. Instead, it is an accounting unit and its profit passes through to its partners and is taxed as their personal income. Therefore, the applicant on the tax-at-source refund application must be the partner of the partnership.

Depositary receipts (such as ADRs)

A depositary receipt is an independent financial instrument representing the holder's right to hold shares. Depositary receipts are traded in the stock exchange in the same way as corporate stock. For example, American Depositary Receipts (ADRs) are traded in some stock exchanges in the U.S. (for example, AMEX, NYSE and Nasdaq).

If the application concerns dividends that were paid on the basis of a depositary receipt, enclose a free-form account of the matter with the application. Also enclose a receipt of dividend payment, issued to the holder of the depositary receipt. Please note that the Tax Administration pays the refund in euros, even if the dividends were paid in another currency.