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

Applications arriving at the Finnish Tax Administration will be scanned using optical character recognition, i.e. converted into digital form. Because of this, it is important that you do not add any stamps, text or the like close to the QR code to the application form.

You can use one-sided or two-sided printing when printing out the form, and you can fill in the form manually if you prefer.

Send the completed form to the address stated at the top of the form. Alternatively, take the application to a Finnish Tax Administration service point.

Attach the following documents to the application:

• A proof showing that the applicant owns the Finnish company’s shares: for example, a portfolio report issued by a bank or other stock broker, specifying the applicant’s Finnish holdings. The proof must be recent and issued during the same year for which a tax-at-source card is requested.
• A certificate of fiscal residence issued by the tax authority of the applicant’s country of residence for the current year or, in exceptional cases, another official registration document, such as an UCITS certificate.
• A power of attorney if the applicant is represented by an agent.
• Grounds for the tax-at-source rate requested, including a detailed and extensive description of the applicant (see section 3.7 and 3.8 of the instructions), if the application’s legal basis is other than the tax treaty between the applicant’s country of residence and Finland. The grounds are a mandatory part of the application.
  • If the application is based on the applicant being comparable to a Finnish tax-exempt investment fund or special investment fund, attach grounds stating why this is so.
• The contract on which the royalties are based if you are requesting a tax-at-source card for royalty income.

Note: Even if the applicant has been previously issued a tax-at-source card or has requested and received a refund, you must still attach grounds for the requested tax-at-source rate to the application.

The tax-at-source card issued by the Tax Administration has the information in Finnish, Swedish and English. Select the language of the form according to the language in which you would like to receive any requests for additional information and detailed grounds for the tax-at-source card issued:

• application form in Finnish
• application form in Swedish
• application form in English

1 Applicant

1.1 Official name

Enter the applicant’s official name, i.e. enter the name in the same way as it is written on the applicant’s certificate of fiscal residence or some other official document. You may also attach a sticker with the applicant’s official name to the form. If necessary, the text or sticker may exceed the space reserved for it in field 1.1 of the form.

If the applicant's name has changed, report the change in a separate enclosure. The enclosure must state the date of the change of name.

1.2–1.3 Tax identification number (TIN) or other registration number in country of residence

Enter the applicant’s official tax identification number in the country of residence. The identification number must be the same as in the applicant’s certificate of fiscal residence or other official document.

If the applicant does not have a tax identification number issued by the country of residence, attach a free-form account explaining this and fill in field 1.3 Other registration number in country of residence. Do not enter the fund management company’s identifier, for example, in this field.

1.4–1.6 Address

Enter the postal address, postal code and post office in the appropriate fields. If the applicant’s postal address is not in the applicant’s country of residence, enter the country of the postal address in field 1.6. You can attach an address sticker to the form but it must stay inside the frames of the appropriate field.

If the applicant does not have an agent or representative, the Tax Administration will send the tax-at-source card and any information requests to the address you enter here.

1.7–1.8 Country of residence

Enter the applicant’s country of residence. The country of residence must be the same as the country that issued the certificate of fiscal residence or other registration certificate to the applicant.

Also enter the country code for the applicant’s country of residence (field 1.8). A non-resident taxpayer’s country of residence cannot be Finland (FI). Enter the country code according to ISO 3166 (www.iso.org). You can check the country code on the page Tax treaties, for example. Note, however, that only the countries that have a tax treaty with Finland are listed on the page.

1.9-1.10 Legal form of  applicant

Enter the applicant’s legal form in field 1.9. You can enter the legal form in the language of the applicant’s country of residence: for example, “fonds commun de placement (FCP)”. State the legal form as accurately as possible.

In 1.10, specify what kind of corporate entity the applicant is by ticking the appropriate box. You can select only one option. If none of the options given describes the applicant, select 9 Other.

1.11–1.12 Public listing

A company is listed on a stock exchange if any of its shares are publicly listed, i.e. traded on a regulated market supervised by authorities. Select the appropriate option in 1.11 depending on whether the applicant is a listed or non-listed company on the date when the application is submitted. If the applicant is publicly listed, enter the applicant’s ISIN code in field 1.12. If the applicant does not have an ISIN code, leave the field blank.

If the basis of the application is that dividends paid by a publicly listed company to another publicly listed company are exempt from tax, attach a free-form account specifying the stock exchange where the applicant company’s shares are listed and publicly traded.

1.13 The applicant is the main entity of an umbrella fund

Tick a box in this field only if the applicant is part of an umbrella fund. If the applicant is an umbrella fund’s main fund, select Yes. If the applicant is a sub-fund, select No.

For more information, see Tax-at-source card applications for umbrella funds at the end of these instructions.

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

This form is primarily for non-resident foreign corporate entities that do not have a permanent establishment in Finland. If the applicant has a permanent establishment in Finland and the income is attributable to it, the income and the tax at source withheld on the income must be filed on the income tax return (Form 6U). 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 any information requests to your agent, enter the agent’s name, company and address in this section. If the applicant is represented by more than one agent, enter the details of the agent that the applicant wants us to send any information requests to, even if a different agent has signed the application.

If you also want the tax-at-source card to be sent to the agent specified in this section, select Yes in field 2.6 “Tax-at-source card will be delivered to the agent”.

Attach a power of attorney issued to the agent to the application, and tick box 2.8. The person signing the power of attorney must have the right to sign for the applicant.

2.2 Representative’s identifier

Based on the agent’s or representative’s identifier, the Tax Administration can separate the tax-at-source applications submitted by a certain agent from other applications. Based on the identifier, the Tax Administration can also check the status of all the applications submitted by a certain agent. The identifier may be a Business ID, a tax identification number (TIN) issued by another country, or an identifier issued by another 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 applicant has previously been issued a tax-at-source card, select Yes and enter the decision number on the tax-at-source card in field 3.2.

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

If the applicant has previously received a decision on a tax-at-source refund from the Tax Administration, select Yes and enter the decision number in field 3.4.

3.5 Have there been changes to the circumstances described in earlier applications?

If the applicant has previously received a decision on a tax-at-source card or tax-at-source refund, select Yes or No, depending on whether the applicant’s circumstances described in previous applications have changed. If you select Yes, attach a detailed description of the changes, such as a change of name or amendments made to the legislation of the country of residence.

Note: Even if the applicant’s circumstances have not changed since the previously issued tax-at-source card or refund decision, grounds for the requested tax-at-source rate must still be attached to the application if the applicant has selected that the application is “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 a tax-at-source card for the current calendar year. For example, if you are requesting a tax-at-source card for dividend income you will receive in 2027, enter 1.1.2027–31.12.2027 in this field.

3.7 Tax-at-source rate

Enter the tax rate you are requesting for the tax-at-source card. Enter the rate in numbers, such as 0 or 15.

3.8 Grounds for the application

Enter here on what basis you are requesting a tax-at-source card. If the application is based on a tax treaty between Finland and the applicant’s country of residence, select “based on tax treaty between Finland and applicant’s country of residence”. The applicant’s certificate of fiscal residence must clearly state that the applicant is a resident taxpayer in the country of residence under the tax treaty.

Select “based on EU Law” if the applicant refers to the fundamental freedoms of the European Union, such as the free movement of capital or the free right of establishment, and holds that the taxation at source is discriminatory. Also select this option if the application is based on an EU directive, or if the applicant is comparable to a Finnish tax-exempt entity. Attach a free-form account explaining why the applicant’s tax treatment is discriminatory as compared with a corresponding Finnish entity. The account must also contain a more detailed description of the applicant and its activities.

In other cases, select “based on other reason”. Even then, attach a free-form account providing detailed grounds.

3.9–3.11 Details of the Finnish payor

If you are requesting a tax-at-source card for specific dividend, interest or royalty income, state the name and Business ID of the Finnish payor.
If you are requesting a tax-at-source card for use by several payors, select Yes in field 3.11. The tax-at-source card issued will then state that the payor is “Finnish listed companies”.

3.12 Application concerns income from

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

Note: In one application, you can request a tax-at-source card for only one income type. For example, if you are requesting a tax-at-source card for dividend income, you cannot request a tax-at-source card for interest income with the same application.

4 Share lending and beneficial owner

Fill in these fields only if at least one income item has already been paid. 
Select Yes or No in fields 4.1-4.4 depending on the income type and the applicant’s circumstances. If the applicant has already received the income but you leave the fields empty, attach a free-form account of the matter to the application.

Dividend income

4.1 Is the applicant the beneficial owner?

Select Yes in field 4.1 if the applicant is the beneficial owner of the dividends specified in the application and if the shares are not part of a contractual arrangement. Fill in this field only if the application is based on a tax treaty between Finland and the applicant’s country of tax residence.

4.2–4.3 Are the shares part of a lending agreement or some other contractual arrangement?

Select Yes in 4.2 and 4.3 if all or some of the shares referred to in the tax-at-source card application are part of a total return swap, a futures contract or other derivative contract, or if the shares are lent to another party or if they are part of some other contractual arrangement. Fill in these fields regardless of the basis of the application for a tax-at-source card.

If you selected Yes in either 4.2 or 4.3, attach a copy of the contract on the lending agreement or other arrangement and a free-form account explaining why the applicant regards itself as the beneficial owner of the dividends.

4.4 Does the applicant have rights to the shares?

Select Yes in field 4.4 if the applicant has an unlimited right to the shares and their profits. If you select No, attach a free-form account explaining why a tax-at-source card should nevertheless be issued to the applicant.

Interest or royalty income

4.1 Is the applicant the beneficial owner?

Select Yes in field 4.1 if the applicant is the beneficial owner of the interest or royalty income specified in the application. If necessary, attach a free-form account of the grounds why the applicant regards itself as the beneficial owner of the income specified in the application.

4.2–4.4 Are the shares part of a lending agreement or some other legal or contractual obligation, and does the applicant have rights to the shares?

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

Enter the contact information of the agent or other person representing the applicant. Here you can specify the contact details of the person whom the Tax Administration can contact about your application.

Attach the certificate of fiscal residence issued by the tax authority of the applicant’s country of residence to the application and select “Certificate of residence or registration certificate issued by officials in the applicant’s country is enclosed”. The certificate of fiscal residence must apply to the year for which a tax-at-source card is requested.

If the tax-at-source card application is based on grounds other than a tax treaty, the Tax Administration can accept an official registration certificate issued to the applicant instead of a certificate of fiscal residence.

If the applicant cannot obtain a certificate of fiscal residence or other official registration certificate from a relevant authority, do not tick the box. Instead, attach a free-form account explaining why no certificate of fiscal residence or registration certificate has been issued to the applicant.

If your tax-at-source card application is based on the applicant’s comparability to a Finnish investment fund or special investment fund exempted from tax, also enclose grounds explaining why this is so. Before entering the grounds, read the Tax Administration’s detailed guidance On the taxation of investment funds and the provisions of section 20a of the Income Tax Act as regards the conditions for tax exemption of investment funds and special investment funds.

Include at least the following matters in your statement of grounds:

• Specify whether your claim is based on the fund’s comparability to an investment fund in accordance with the UCITS directive or to a special investment fund in accordance with the AIFM directive. 
• The fund’s legal form in its 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. contractual agreement or company by-laws).
• Specify the authority supervising the operations of 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 close-ended? If the fund is open-ended with variable capital, state how and how often unit holders can subscribe for and redeem fund units.
• Specify to whom  fund units are offered , and how investments are made in the fund.
• Enter the exact number of direct unit holders at the time when the application is submitted. Report separately the unit holders who hold their units through a nominee register. If you cannot state the exact number of unit holders, please explain how it has been established that the possible requirement of 30 unit holders is met. State what documents and data have been used in the process. Enclose copies of the documents.

In the case of a special investment fund, also provide the following information if needed: 

• Indicate whether the fund’s unit holders are professional investors or high net worth individuals treated as such. 
• The fund’s capital. 
• State whether the fund is obligated by law to distribute the profits of the accounting period to its unit holders.

The applicant requesting a tax-at-source card must be the party who is considered to be the taxpayer under Finnish national law. Tax liability is defined according to Finland’s national legislation. Corporate entities are separate taxpayers, whereas a partnership is an accounting unit and its shareholders are liable for paying income tax.

Read more about the concept of corporate entity in chapter 2 of the Tax Administration’s detailed guidance Resident and nonresident tax liability of corporate entities.

Submit the application in the name of the flow-through corporate entity to which the income is initially paid.

If the application for a tax-at-source card is based on the tax treaty between Finland and the underlying unit holders of the flow-through corporate entity, enclose an account stating that the tax treaty can be applied to the income received by the unit holders.

An umbrella fund is a fund divided into multiple sub-funds that are legally part of the main fund. In other words, from the legal point of view, there is only one fund.

Fill in the tax-at-source card application in the name of the sub-fund if the tax-at-source card application is based on the applicant’s comparability to a Finnish tax-exempt investment fund or special investment fund. Finnish investment funds can also have a sub-fund structure, and the criteria for fulfilling the tax exemption are evaluated at the sub-fund level. Attach a separate account explaining that the applicant is a sub-fund of an umbrella fund.

If your application for a tax-at-source card is based on the tax treaty or other reason, fill in the application in the name of the corporate entity to which the certificate of fiscal residence has been issued. In addition, attach a separate account stating whether the applicant is the main fund or a sub-fund of the umbrella fund.