Foreign corporation's tax-at-source card application for dividend, interest and royalty income (Form 6211e), how to fill out the form
These instructions should only be followed in situations where a foreign corporate entity is applying for a tax-at-source card for dividends, interest or royalties (Form 6211e). You can download the form 6211e on Forms.
One completed application can only contain one category of income that the tax-at-source card will concern. It is important to specify the correct category. If the income falls under other categories such as non-wage compensation for work, “trade income”, etc. and is not dividends, interest or royalties, submit Form 6202e instead.
Applications for tax-at-source cards can also be submitted electronically. You can use these same instructions when filling in an electronic application. Go to the e-service to complete the electronic form for this application. Electronic applications can be submitted by foreign corporate entity or by agent or representative acting on their behalf. Bulk submissions can also be submitted to the Tax Administration through Ilmoitin.fi. A bulk submission consists of multiple applications, which are sent in XML format.
The corporate entity can deliver the tax-at-source card to the payer before the income is paid. This allows the payer to withhold the right amount of tax-at-source. In cases where the payment has already been made and too much tax was withheld upon payment, the corporate entity still has the option to ask for a “Quick Refund" from their custodian bank with the card. “Quick Refund” must be done before the year end. In both of the above circumstances, there is no need for the corporate entity to submit an application for a tax-at-source refund to the Tax Administration after the payment year.
In general, the Tax Administration issues tax-at-source cards for the current calendar year.
Completing and submitting the application
The cards are made out in Finnish, Swedish and English, with all the 3 languages on the card. You can select from Finnish, Swedish or English application forms. The language you use for filling out the form is the language in which you will receive additional information requests and the decision outlining the legal grounds for issuing you the card.
We recommend that you familiarize yourself with the in-depth guide on dividends, interest and royalties paid to nonresident beneficiaries before you proceed to fill in the fields.
Enter the information into the fields of the application form carefully. Each field is for a specific item of information. Please follow the instructions and only give the required details specified for each field. For example, the street address, postal code and post office should be separate from one another. Some entries can be made by attaching a sticker on the form (this may be convenient for addresses or bank f numbers and bank’s address). 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.
You can print out the form on one page or on two pages. If you prefer, you can complete it by hand.
Send the completed application form to the address stated at the top of the form. If it is more convenient, you can deliver it to any office of the Finnish Tax Administration, or to the Finnish Tax Administration, Registry, Vääksyntie 4, 00510 Helsinki.
Remember the enclosures and the basis for the application
Include in the application:
- Proof of being a shareholder of a Finnish company. This may be an extract from your portfolio statement, issued by an asset-management service or bank. The statement must be recent. As a minimum, it must be issued the same year when you are submitting the application for the card.
- A certificate of residence issued during the current year. Under exceptional circumstances, other registration document from local officials will also be accepted (for more information, see certificate of residency or registration, issued by home-country authorities).
- If you are submitting an application that is not based on the tax treaty between the applicant’s country of residence and Finland, enclose a free-form account indicating the grounds for the application and containing a detailed description of the applicant (for more information, see 3.7 to 3.8 of the instructions)
- A power of attorney if the applicant is represented by an agent or a representative.
Other, additional documentation may be required. The extent of documentation depends on what the grounds for your application are. You are free to enclose still further documentation if you consider it useful. For example, if the corporate entity has changed its name, enclose a separate document to give details on the name change.
Note: Even if the corporate entity had been issued a tax-at-source card previously, and even if corporate entity had received a refund previously, you must still enclose the reasoning for your desired rate of withholding of tax-at-source. If you refer to a previous decision, you must also enclose a written affirmation that the applicant’s circumstances have not changed.
How to complete form 6211e
1.1 Applicant’s official name
Enter the name of the applicant; spell it the same way as it is spelled in the applicant’s certificate of residence or other official document.
1.2–1.3 Tax identification number or other registration number in the country of residence
Indicate the tax identification number, TIN, issued by the applicant’s country of residence. This identification number must be the same as that showing on the certificate of residence or other similar document.
If the country has not issued a tax identification number (TIN) for the corporate entity, enclose a written account explaining this, and fill a registration number or other identity code, issued by the country of residence, in field 1.3.
1.4–1.6 Postal address
The street i.e. postal address, postal code and post office must go to their proper fields. If the applicant’s country of tax residence is different from the country of its postal address, enter the name of the country in field 1.6 as appropriate.
If the corporate entity is not represented by a representative, the business address you fill in here will be the one that the Tax Administration will use for correspondence and for sending you the tax-at-source card and any letters in order to ask you to provide further information for the application.
1.7–1.8 Country of residence
Fill in the name of the country. It should be the same as the country that issued the certificate of residence (or other document proving registration) to the corporate entity.
The country code is required (fill it in field 1.8). Please note that the country of residence of a nonresident taxpayer cannot be Finland (FI).
Enter the country code as defined in the ISO 3166 standard (www.iso.org). You can check the country code on Tax treaties. However, only the countries that have a tax treaty with Finland are shown on that page.
1.9 Legal form
The corporate entity’s legal form must be filled in field 1.9. You can enter it in the language of the country of residence: for example, “fonds commun de placement (FCP)”. Inform the form of legal entity in exact terms.
Under “1.10 The applicant is...”, tick the correct box to describe what kind of the corporate entity the applicant is. You can select only one. Select “9 Other” if the remaining boxes are not appropriate.
Example: The applicant is a fund within the meaning of the Directive on undertakings for collective investment in transferable securities. Its legal form in its country of residence is “fonds commun de placement” (FCP). Accordingly, enter “fonds commun de placement” in field 1.9, and tick the “5 UCITS” box under 1.10.
1.11–1.12 Information on listing on a stock exchange
A company is publicly listed if any of its shares, which may be issued as sets of different series, are listed on a stock exchange and traded on a regulated marketplace. Tick the box depending on whether the applicant is stock exchange listed or not listed at the time when you complete this application form. If the applicant is listed, please enter the applicant’s ISIN code in field 1.12. Leave blank if the applicant has no ISIN code.
If the basis for the application is that dividends paid by a publicly listed company to another publicly listed beneficiary are tax-exempt, give the name of the stock exchange where the applicant’s shares are listed and publicly traded.
1.13 The applicant is the main entity of an umbrella fund
Only fill in this field if the applicant is part of an umbrella fund. Tick “Yes” if the applicant is an umbrella fund’s main fund. If it is a sub-fund, tick “No”.
For more information, see Tax-at-source cards for umbrella funds below.
1.14 Is the applicant treated as having a permanent establishment in Finland?
This form is primarily for foreign corporate entities with no permanent establishment in Finland. If a permanent establishment is formed for the applicant, and the income concerned by the application is attributable to that permanent establishment, the income and the tax withheld at source on it must be reported on Form 6U, the income tax return. Further information on permanent establishments in income taxation.
2 Information on the agent or representative signing this application form
If you want the Tax Administration to send the requests for further information to the agent or representative, enter its name and address here. If more than one agent or representative are representing the applicant, you should enter the name and address of the one who can respond to any request letters for additional information that the Tax Administration may send; although it may be that another representative has signed the application form.
If you prefer, the card can be delivered to the agent or representative. Tick the box in field 2.6 accordingly.
A power of attorney must be enclosed. Tick the box in 2.8 to show that it has been enclosed. It must be authorised with the signature of someone who has the right to sign for the applicant.
2.2 Representative’s identifier
The representative’s identifier makes it possible for the Tax Administration to distinguish the tax-at-source applications submitted by a certain agent or representative from all other applications. It also makes it possible, for every agent or representative, to check their applications’ current stage of processing.
The identity code for field 2.2 may be a Finnish Business ID, a Tax Identification Number (TIN) issued by a foreign country, or another ID code issued by some other public authority.
3 Details on the tax-at-source card
3.1–3.2 Has the applicant been issued a refund decision before?
Correspondingly, if the applicant has been issued a tax-at-source refund decision earlier, enter the Tax Administration's decision number in field 3.4.
3.3–3.4 Has the applicant been issued a refund decision before?
Correspondingly, if a refund has been decided on before and the corporate entity has received the decision letter, enter the decision number in field 3.4.
3.5 Have there been any changes in the circumstances described in earlier applications?
If the corporate entity has received a tax-at-source card or a refund earlier, you should indicate whether its circumstances, presented earlier, have changed or remained the same – tick either ”Yes” or ”No”. If you answered “Yes” and the circumstances have changed, please write up a free-form account. Changes like a name change, or amendments to relevant laws in the country of residence should be accounted for.
Please note that even if no changes had occurred that would have concerned the entity’s circumstances since its previous tax-at-source card or refund, it is still required for the application to contain a reasoning for the requested rate of the tax to be withheld at source if you had ticked the “based on EU Law” box or the “based on other reason” box.
3.6 Time period for which the tax-at-source card is requested
In general, the Tax Administration issues tax-at-source cards for the current calendar year. This means that if you need one for dividends that will be paid to you in 2022, fill in 1.1.2022–31.12.2022 in this field.
3.7 The tax-at-source card is requested with rate
This field is for the desired tax-at-source percentage. Fill in a number: 0 or 15 etc. to the field 3.7.
3.8 Basis for the application
This field is for indicating the legal grounds of your application. If you are submitting your application based on the tax treaty between Finland and the applicant’s country of residence, tick ”based on tax treaty between Finland and applicant’s country of residence”. It must be clearly stated on the entity’s certificate of residence that the applicant is subject to tax within the meaning tax treaty between Finland and the applicant's country of residence.
If the entity is submitting the application based on the fundamental freedoms of the European Union – free movement of capital, free right of establishment – and has regarded the Finnish taxation at source as discrimination, tick the “based on EU Law” box. If the application is based on an EU Directive or generally that the applicant can be found comparable to a tax-exempt Finnish entity, tick the “EU Law” box also in that case. In the above circumstances, enclose a free-form account for the basis. The reasoning must indicate the facts that constitute discriminatory tax treatment when compared to the taxation of a comparable Finnish entity. In addition, the account must contain a more detailed description of the applicant and its activities.
The “other reason” box should be ticked if the basis is none of the above. Even in this case, please enclose a free-form account to provide further explanation of the basis.
Example: A French “fonds commun de placement” (FCP) is not the type of entity that is entitled to tax-treaty benefits. Because of its quantity of shareholders, the FCP is not comparable with a Finnish investment fund either. However, an FCP can apply for a tax-at-source card based on another reason. The application must include reasoning on which the applicant can demand that 20-percent corporate tax-at-source rate should be applied on the applicant’s receipts of income.
3.9–3.11 Information about the Finnish payer
If the card is requested only for a specific dividend, interest or royalty income, fill in the payer's name and Business ID.
If more than one payer is involved, tick “Yes” under 3.11. The phrase to be shown on your card will in this case be “Finnish listed companies”.
3.12 Application concerns income from
Choose the appropriate box to tick.
Note: One completed application can only contain one type of income. For example, if you apply for a tax-at-source card for dividend income, you cannot request another tax-at-source card for interest income with the same application. To do that, you must submit another application.
4 Share lending and beneficial owner
This section is only for applicants that already have received at least one amount of the income concerned by the application. Tick "Yes" or "No" in boxes 4.1–4.4 as appropriate, taking account of the category of income and the applicant’s circumstances. If you have already received the income but you leave the boxes unticked, please enclose a free-form account of your circumstances.
4.1 Is the applicant the beneficial owner?
You must tick “Yes” in field 4.1 if the applicant is the beneficial owner of the dividends mentioned in the application, and the shares are not part of some sort of legal or contractual arrangement. Fill in field 4.1 only if you are filing the application based on the tax treaty between Finland and the applicant's country of residence.
4.2–4.3 Are the shares part of a lending or contractual agreement?
Tick “Yes” in field 4.2 and field 4.3 if the shares held and referred to in the application are, fully or partially, part of a total return swap, a futures contract or some other derivative contract, or if the shares are lent to another party or are part of some other arrangement. Fill in these fields regardless of the basis of the application for a tax-at-source card.
If you answered “Yes” to either 4.2 or 4.3, please enclose the agreement on the lending or contractual obligation and a free-form account as to how and why the applicant sees themselves to be the beneficial owner of the dividends mentioned on the application.
4.4. Does the applicant have rights to the shares?
Tick “Yes” in field 4.4 if the applicant has unlimited rights to the shares and their profits. If you answered “No” to 4.4, please enclose a free-form account why a card should be issued to the applicant.
Interest and royalty income
4.1 Is the applicant the beneficial owner?
You must tick “Yes” in field 4.1 if the applicant is the beneficial owner of the interest or royalty income mentioned in the application. If necessary, enclose a free-form account as to how and why the applicant sees themselves to be the beneficial owner of the income mentioned on the application.
4.2–4.4 Are the shares part of a lending or contractual agreement?
Leave fields 4.2 to 4.4 blank if the application concerns interest or royalties.
Contact details for more information (person to contact)
Either fill in the agent’s or representative’s information, or that of some other party who is representing the applicant. You can fill in this field with precise information of the contact person who The Finnish Tax Administration can contact for further information for processing your application.
After you enclose the certificate of residence, tick the box for “Certificate of residence or registration certificate issued by officials in the applicant’s country is enclosed”. The certificate of residence must be issued for the tax year you are requesting the tax-at-source card.
If your application is based on other grounds than a tax treaty, the Finnish Tax Administration can accept an official registration certificate issued to the applicant instead of a certificate of residence.
If the applicant cannot obtain a certificate of residence or other official registration certificate, leave the box unticked. Instead, provide the Tax Administration a free-form account giving the reason why no certificate of residence or other registration certificate were issued.
Additional guidance for investment funds and flow-through units
The impact of the amended Act on Investment Funds on the procedure of issuing tax-at-source cards
In February 2019, the Finnish Parliament adopted the Government Proposal on the Act on Investment Funds (Sijoitusrahastolaki 213/2019) and related legislation (Government Proposal 243/2018). The provisions of the legislative amendment are applied as of 1 January 2020. The amendment clarifies the terms “investment funds” and “special investment funds”. Criteria for investment fund's and special investment fund's tax exemption are clarified in the Income Tax Act (Tuloverolaki 1535/1992) and in the Act on the Taxation of Nonresidents' Income (Laki rajoitetusti verovelvollisen tulon verottamisesta 627/1978).
The amendment has an impact on how foreign investment funds requesting a tax-at-source card are evaluated in comparison to Finnish investment funds. For this reason, investment funds are required to review if they meet the conditions of tax exemption, even if the fund has received a tax-at-source card or refund decision earlier.
For more information, see the Tax Administration’s detailed guide On the taxation of investment funds and the provisions of section 20a of the Income Tax Act.
Income received through a flow-through unit
Even in cases where the income is paid through a flow-through entity to the beneficiary, the flow-through entity should be the party applying for a tax-at-source card. The applicant should be the party who is considered to be taxpayer under Finnish national law. Therefore, the tax-at-source card should be applied by the party to whom the income was paid at first.
If your application for the tax-at-source card is based on the underlying investor's tax treaty provisions, enclose documentation to prove that these owners are entitled to tax treaty benefits. Also, in this case, you should fill out the application in the name of the flow-through entity.
Example: 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.
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.
As of 1 January 2020, a Finnish investment fund can also be formed in an “umbrella” structure and the criteria for fulfilling the tax exemption are evaluated at the sub-fund level. You should fill out the application in the sub-fund’s name, if your application is based on the applicant's comparability to a Finnish tax-exempt investment fund. Add an additional account of the sub-fund belonging to an umbrella fund.
Note: If your application for the tax-at-source card is based on tax treaty provisions or on another reason, fill out the application in the entity’s name that has been issued the certificate of residence. In this case, enclose information on whether the applicant is the main fund or one of the sub-funds.