Foreign corporation's tax-at-source card application for dividend, interest and royalty income (Form 6211e), how to fill out the form

General instructions

These instructions are intended only for situations where a non-resident foreign corporate entity is applying for a tax-at-source card for dividends, interest or royalty income (Form 6211e). Download Form 6211e from the Forms page. If the income falls under other categories such as non-wage compensation for work, “trade income”, etc. submit Form 6202e instead.

One application can only contain one category of income that the tax-at-source card will concern. It is important to specify the correct income category in the application.

Applications for tax-at-source cards can be submitted electronically. You can use these same instructions when filling in an electronic application. File a single application in MyTax. After logging in, select Report or request information in a limited scope. Applications can be submitted by the foreign corporate entity or by an agent or representative acting on its behalf. 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 applications for tax-at-source cards.

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

In general, the Tax Administration issues tax-at-source cards for the current calendar year only. It is possible to deviate from this rule in certain circumstances. For example, if the fund has been established in the middle of the current calendar year, the tax-at-source card will be issued from the fund’s establishment date to the end of the calendar year.

Please note that a tax-at-source card is not needed for requesting a tax-at-source refund from the Tax Administration. Further, tax-at-source cards cannot be issued retroactively for past calendar years. If you need a tax-at-source card for the current calendar year, submit an application to the Tax Administration by mid-November at the latest. Note that the account operator may also have their own deadline after which “quick refunds” can no longer be made for the year of payment.

Completing and submitting the application

Tax-at-source cards are issued in Finnish, Swedish and English, with all the 3 languages on the card. You can submit the application in Finnish, Swedish, or English. If the Tax Administration needs to request additional information from you, you will receive the information request in the same langauge as the language of your application form. The Tax Administration will also use the same language in the decision outlining the legal grounds for issuing the tax-at-source card.

Before filling in the application, read the detailed guidance on dividends, interest and royalties paid to non-resident beneficiaries.

Please fill in the fields of the application carefully. Each field on the form is reserved for a specific piece of information. Fill in only the required details specified for each field. For example, the street address, postal code and post office must be entered in their own separate fields. 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.

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. 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:

• 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 and issued for the same year as the tax-at-source card is applied.
• A certificate of residence (COR), issued during the current year. Under exceptional circumstances, some other registration document from local officials (e.g. UCITS certification) will also be accepted (for more information, see certificate of residency or registration, issued by home-country authorities).
• A power of attorney if the applicant is represented by an agent or representative.

• 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 requested tax-at-source rate and containing a detailed description of the applicant (for more information, see 3.7 to 3.8 of the instructions).

  • If the basis for the application is that the applicant should be found comparable to a Finnish tax-exempt investment fund or special investment fund, also 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 royalty agreement, if the tax-at-source card is being requested for royalty income.

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 has been issued a tax-at-source card previously or has received a tax-at-source refund, grounds for the applied tax-at-source rate must still be enclosed with the application.

Detailed instructions for filling in Form 6211e

1. Applicant

1.1 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.

1.2–1.3 TIN or other registration number in the country of residence

Enter 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 tax residence or other similar document.

If the country has not issued a TIN for the corporate entity, enclose a free-form account explaining this, and enter a registration number or other identity code, issued by the country of residence, in field 1.3.

1.4–1.6 Postal address

Fill in the postal address, postal code and city in the appropriate 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 the tax-at-source card and any additional information requests.

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 non-resident 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 the page Tax treaties. However, only the countries that have a tax treaty with Finland are shown on that page.

1.9 Legal form of applicant

The foreign corporate entity’s legal form must be filled in field 1.9. You can enter it in the language of the country of residence: “fonds commun de placement (FCP)”, for example. Specify the form of legal entity in exact terms.

In section 1.10, tick the correct box to describe what kind of entity the applicant is. You can select only one. Select “9 Other” if the remaining boxes are not appropriate.

Example 1: The applicant is an investment fund within the meaning of the Directive on undertakings for collective investment in transferable securities (UCITS). 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, 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 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 publicly listed, 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 company 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 non-resident foreign corporate entities with no 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). Further information on permanent establishments in income taxation.

2 Information on the representative signing the application

If you want the Tax Administration to send the decision and any requests for further information to an agent or representative, enter their name and address here. If the applicant is represented by multiple agents or representatives, enter the name and address of the one who is to receive the information requests, even if 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.

Enclose a power of attorney issued for the agent and tick the box in 2.8. The person signing the power of attorney must have the right to sign for the corporate entity.

2.2 Representative’s identifier

The representative’s identifier makes it possible for the Tax Administration to distinguish the refund applications submitted by a certain agent or representative 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 Details on the tax-at-source card

3.1–3.2 Has the applicant been issued a tax-at-source card before?

If the corporate entity has been issued a tax-at-source card earlier, tick “Yes” and enter the decision number in field 3.2.

3.3–3.4 Has the applicant been issued a refund decision before?

If the corporate entity has been issued a tax-at-source refund earlier, tick "Yes" and 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, tick either "Yes" or "No" to indicate whether its circumstances, presented in earlier applications, have changed or remained the same. If you answered “Yes”, enclose a free-form account of the changes. Changes like a name change, or amendments to relevant laws in the country of residence should be accounted for.

Note: Even if no changes had occurred that would have concerned the entity’s circumstances since its previous tax-at-source card or refund decision, it is still required to enclose grounds with the application for the requested tax-at-source rate if you had ticked the box “based on EU Law” or “based on other reason”.

3.6 Time period for which the tax-at-source card is requested

In general, the Tax Administration issues the tax-at-source card for the current calendar year. For example, if you need a tax-at-source card for dividends that will be paid to you in 2024, fill in 1.1.2024–31.12.2024 in this field.

3.7 Tax-at-source rate

This field is for the desired tax-at-source rate. Enter a percentage rate as a number, such as 0 or 15.

3.8 Basis for the application

This field is for indicating the basis for the application. If the application is based on the tax treaty between Finland and the applicant’s country of tax residence, tick “based on tax treaty between Finland and applicant’s country of residence”. It must be clearly stated on the corporate entity’s certificate of residence (COR) that the applicant is subject to tax within the meaning of the tax treaty between Finland and the applicant's country of residence.

If the entity 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 will be discriminated in taxation at source, tick the box “EU Law”. If the application is based on an EU Directive, or generally that the applicant is 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 of the application. The free-form account 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. Also in this case, please enclose a free-form account to provide further explanation of the basis.

Example 3: A French “fonds commun de placement” (FCP) is not the type of entity that is entitled to tax treaty benefits. Because of the number of unit holders subscribed to the fund, the fund is not comparable to a Finnish tax-exempt investment fund. However, the fund can apply for a tax-at-source card based on "other reason". Grounds must be enclosed with the application. The applicant can, for example, demand that a 20% 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 some 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...

Indicate whether you are requesting a tax-at-source card for dividend income, interest income, or royalty income.

Note: One application can only concern one category of income. For example, if the tax-at-source card is applied for dividend income, the same application form cannot be used to request a tax-at-source card for interest income. To do that, submit another application concerning interest income.

4 Share lending and beneficial owner

Fill in these sections only if you have already 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 into account the category of income and the applicant’s circumstances. If the income is already received but you leave the boxes unticked, enclose a free-form account of the circumstances.

Dividend income

4.1 Is the applicant the beneficial owner?

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 corporate entity’s country of tax residence.

4.2–4.3 Are the shares part of a lending agreement?

Tick “Yes” in field 4.2 and field 4.3 if the shares held and referred to in this application are, fully or partially, part of a total return swap, a futures contract or other derivative contract, or if the shares are lent to some other 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, enclose the agreement on the lending or contractual obligation with a free-form account as to how and why the applicant sees itself  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”, enclose a free-form account why a tax-at-source card should be issued to the applicant.

Interest and royalties

4.1 Is the applicant the beneficial owner?

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 itself to be the beneficial owner of the income mentioned on the application.

4.2–4.4 Are the shares part of a lending agreement, and does the applicant have rights to the shares?

Leave fields 4.2 to 4.4 blank if the application concerns interest or royalties.

Contact details for more information

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 the application.

Certificate of fiscal residence or other registration certificate issued by the country of residence

Enclose the certificate of residence (COR) with the application and tick the box for “Certificate of residence or registration certificate issued by officials in the applicant’s country is enclosed”. The COR must be issued for the tax year for which the tax-at-source card is requested.

If the application is based on other grounds than a tax treaty, an official registration certificate issued to the applicant can be accepted instead of the COR.

If the corporate entity cannot obtain a certificate of residence or other official registration certificate, leave the box unticked. Instead, enclose a free-form account giving the reason why no COR or other registration certificate were issued.

Additional guidance for investment funds and flow-through units

Applicant comparable to a Finnish investment fund

If the basis for the application of a tax-at-source card 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 fund holder can redeem its shares fund units. 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 has. 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.

Income received through a flow-through corporate entity

Even if the income is ultimately paid through a flow-through corporate entity to the beneficiary, the application for a tax-at-source card must be made in the name of the flow-through corporate entity. The party requesting the tax-at-source card must always be the party who is considered the taxpayer under Finnish national law. Therefore, the tax-at-source card must be applied by the party to whom the income is paid first.

If the application for the tax-at-source card is based on tax treaty between Finland and the underlying unit holders, enclose documentation to prove that these unit holders are entitled to the tax treaty benefits. In this case too, the application must be completed in the name of the flow-through corporate entity.

Tax-at-source cards for 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.

A Finnish investment funds can also be established in an "umbrella" structure and the criteria for fulfilling the tax exemption are evaluated at the sub-fund level. Fill out the application in the sub-fund’s name, if the 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.

If the application for the tax-at-source card is based on the tax treaty provisions or on other reason, fill out the application in the corporate entity’s name that has been issued the certificate of residence. In this case, enclose a free-form account on whether the applicant is the main fund or one of the sub-funds.