Register of Authorised Intermediaries

A corporation that operates custodial activities may submit an application for entry into the Register of Authorised Intermediaries. Intermediaries can be credit institutions, investment service companies and central securities depositories, for example.

Registration is voluntary for the intermediary, and the application for registration is submitted on the intermediary’s own initiative.

Applications for registration will be accepted as of 1 July 2020. The registration come into force on 1 January 2021 at the earliest.

Requirements for registration

Intermediaries that fulfil the following requirements can be entered in the Tax Administration’s Register of Authorised Intermediaries:

  • The intermediary has a permit issued by an authority to perform custodial activities.
  • The intermediary’s domicile is within the European Union or in a country with which Finland has a treaty for the avoidance of double taxation. 
  • The common information exchange standard, or the Anti-Money Laundering and Know Your Customer regulations are applied to the intermediary along with other legislation based on which the intermediary is obligated to identify its customers and their country of residence for tax purposes.

If, based on its prior neglect, the intermediary can be assumed to neglect its responsibilities as an Authorised Intermediary, or if any previously imposed taxes remain unpaid, entry into the Tax Administration’s Register of Authorised Intermediaries may be refused.

Responsibilities and liabilities of an Authorised Intermediary

Authorised Intermediary has

  • to investigate and ascertain the beneficiary's, who is its customer, right to tax treaty benefits, when tax treaty benefits are granted to the beneficiary.
  • to submit annual information return on the beneficial owner information it has assumed responsibility for.
  • the tax liability of a possible under-withholding on dividends it has assumed responsibility for.

The Authorised Intermediary’s annual information return is submitted every year by the end of January on dividends paid during the previous calendar year. The annual information return is submitted on dividends that are paid by a Finnish publicly listed company to a non-resident beneficiary on the basis of a nominee-registered share.

Register of Authorised Intermediaries

The Register of Authorised Intermediaries will be published on 1 January 2021.

The Register of Authorised Intermediaries replaces the Custodian Register. The Custodian Register is no longer in use after 31 December 2020.

Forms

Guidance