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

The form is available here.

General guidance

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. If your income falls into other categories such as “trade income”, etc., and is not dividends, interest or royalties, see Form 6202e and its instructions instead.

Applications for tax-at-source cards can now be submitted electronically. A foreign corporate entity or an agent acting on their behalf can submit an application through the Tax Administration’s e-filing portal. The Tax Administration also accepts bulk submissions through the Ilmoitin.fi portal. A bulk submission is an XML file containing applications for several applicants. You can utilise these filling instructions when submitting information electronically as well.

Read more on sending electronic applications for tax-at-source cards.

The corporation can present the tax-at-source card to the Finnish payer before the income is paid, allowing the payer to withhold the correct amount when paying. In cases where the payment has already been made and too much was withheld upon payment, the corporation can apply for a “quick refund” from their custodian bank on the condition that it has the card. “Quick refunding” must be done before year end. In both of the above circumstances, there is no need for the corporation to prepare an application for refund after the year of payment has ended.

In general, the Tax Administration issues tax-at-source cards for the current calendar year only.

Required enclosures

When you apply for a tax-at-source card for dividend, interest or royalty income, enclose the following documentation:

  • Proof of your being a shareholder of the Finnish company that distributes dividends. 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 (COR), issued during the current year. Under exceptional circumstances, some other registration document from local officials will also be accepted.
  • A detailed description of the grounds for your application. Also indicate the rate you are applying for as the source-tax rate (for more information, see below, passages 3.6 through 3.7).
  • A letter of authorisation if an agent or representative submits the form.

Other, additional documentation may be required. The extent of documentation depends on what the grounds for your application are. We recommend that you enclose the same documentation that you would enclose with a request for refund (see how to fill out Form 6163e). You are free to enclose additional documentation if you consider it useful.

Note: Even if your corporate entity had been issued a tax-at-source card previously, and even if your corporate entity had received a refund previously, you must still enclose the reasoning for your desired rate of source-tax withholding.

Tax-at-source card in English, Finnish and Swedish

The cards are made out in Finnish, Swedish and English, with all the 3 languages on the card. You can select from English, Finnish and Swedish application forms. The language you use for filling out the form is the language you get in case the Tax Administration must send you a request for additional information. After that, the language remains the same when the Tax Administration sends you the cover letter enclosed with the card, containing the Tax Administration’s decision to issue you the card.

Steps to take

When your application form arrives at the Tax Administration, it will undergo 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 fill it in by hand.

Each field on the form is reserved for a specific piece of information. Please fill in only the required details specified for each field. Please fill in the separate spaces properly: street address, postal code and post office should be separate. Some entries can be made by attaching a sticker on the form (this may be convenient for addresses or bank account 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.

Send the completed application form to the address stated at the top. If it is more convenient, you can deliver it to any office of the Finnish Tax Administration, or to the Southern Finland Corporate Tax Office, Registry, Vääksyntie 4, 00510 Helsinki.

How to complete the form

1 Applicant

1.1 Applicant’s official name

Enter the name of the applicant corporation; spell it the same way as it is spelled in the applicant’s certificate of tax residence or other official document.

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

Fill in the corporate entity’s Tax Identification Number, issued by its country of residence. If the country has not issued a 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

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 uses 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. 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.

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).). To check the relevant code or codes, you can visit Tax treaties that Finland has signed with other countries. However, that page only contains the countries that have a treaty with Finland.

1.9–1.10 Legal form of the applicant

The legal entity form must be filled in field 1.9. You can enter it in the language of the country of residence: enter “fond commun de placement (FCP)” as appropriate. You must inform us of the form of legal entity in exact terms.

Under “1.10 The applicant is...”, tick the correct box to describe the corporate entity being the applicant. 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. Its legal form in its country is “fond commun de placement” (FCP). Accordingly, enter “fond 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

Companies are “listed” on a stock exchange if any of its stock, which may be issued as a set of different series, is subjected to public trading in a regulated market where securities are traded under the supervision of local authorities. 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 listed, please enter the applicant’s ISIN code in field 1.12. Leave blank if the applicant has no ISIN code.

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”.

If the applicant is the main fund, and you want to have a tax-at-source card where the sub-funds are listed, because the withholding rate should be applied on those sub-funds, enclose a list of sub-funds. Tick the appropriate box.

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?

It should be noted that Form 6163e is for foreign corporate entities with no permanent establishment in Finland. If a permanent establishment is formed for the applicant, and income 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

When an agent or representative is hired, the address you fill in here will be the one that the Tax Administration uses for correspondence and for sending the refund decision or any letters requesting you to provide further information for the application. If several agents or representatives are representing the applicant, you should enter the name and address of the one who handles correspondence; 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.

The letter of authorisation (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 corporate entity being the applicant.

2.2 Representative’s identifier

Field 2.2 for the representative’s Business ID or other identity code is not a required field. However, it serves the purpose of creating lists of all the refund applications submitted by the agents or representatives over time. In addition, the Business ID may facilitate any checking of the stages of processing after an application has been submitted. The identity code that you should fill in 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 tax-at-source card before?

If the corporate entity has been issued a tax-at-source card at an earlier date some time in the past, tick “Yes” and enter the decision number of the Tax Administration’s decision in field 3.2.

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 changes to 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 an enclosure. Changes like a name change, or amendments to relevant laws in the country of residence should be accounted for.

Please note that the Finnish amendments to the legal rules governing investment funds, effective from January 2020, are regarded as a change in the prevailing circumstances. For detailed instructions, see below: The impact of the amended Act on Investment Funds to the procedure of issuing tax-at-source cards to beneficiaries.

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 only. This means that if you need one for dividends that will be paid to you in 2020, fill in 1.1.2020–31.12.2020 in this field.

3.7–3.8 Reasons for your request; the desired withholding of source tax

This field is for informing the Tax Administration of the basis for the tax-at-source card. If you are filing your application in reference to 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 has a status as a taxpayer in the country of residence that fulfils the requirements of the relevant tax treaty.

If the corporate entity is submitting the application in reference to 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 a Directive of the EU, tick the “based on EU Law” box also in that case. Enclose a free-text letter to provide further explanation of the basis.

The “other reason” box should be ticked if the basis is none of the above. Enclose a free-text letter to provide further explanation of the basis.

Remember to include the desired percentage of withholding for the tax-at-source card. You are expected to fill in a number: 0 or 15 etc.

3.9–3.11 Information about the Finnish payer

If the card is requested only for some specific dividends, interest or royalty income, you must 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 publicly listed companies”.

3.12 Application concerns income from...

Select the appropriate box to tick.

4 Share lending and beneficial owner

This section is only for an applicant that have received the income already. Tick boxes 4.1–4.4 as appropriate, taking account of the category of income and the applicant’s circumstances.

Income in the form of dividends

4.1 Is the applicant the beneficial owner?

You must tick “Yes” in field 4.1 if the applicant is the actual beneficiary, i.e. the beneficial owner, and the shareholding is not part of an outside contract or arrangement.

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

If the shares held and referred to in this application are, fully or partially, part of a swap deal, a futures contract or other derivative contract, or if the shares are lent to some other party, or if some other arrangement concerns them, tick “Yes” under 4.2 or 4.3. If you answered “Yes” to either 4.2 or 4.3, please enclose a copy of the contract on a lending arrangement, etc., with an additional free-form account providing information on the reasons why the applicant believes it should be treated as the beneficial owner of the dividends.

4.4. Does the applicant have rights to the shares on which dividends were paid to the applicant's account?

If you answered “No” to 4.4, please enclose a document giving the reasons why a card should be issued to the applicant.

If you are not sure of the above facts and circumstances, you can leave these fields blank.

Interest or royalties:

You must tick “Yes” in field 4.1 if the applicant is the beneficial owner of the interest or royalties that your application refers to. If necessary, enclose a free-text explanation as to how and why the applicant believes to be the beneficial owner of the items of income, as specified in the application. Fields 4.2–4.4 may be left blank.

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 corporate entity i.e. the applicant. You must refer to a person to contact. The Finnish Tax Administration may require further information for processing your application.

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

After you enclose the COR, tick the box for “Certificate of residence or registration certificate issued by officials in the applicant’s country is enclosed”. If the applicant cannot, for some reason, obtain a certificate from a relevant tax authority, do not tick this box. Instead, you must provide the Tax Administration with other documentation proving the applicant’s registration and a written account giving the reason why no COR or other certificate on registration was issued.

Additional guidance for investment funds

The impact of the amended Act on Investment Funds to the procedure of issuing tax-at-source cards to beneficiaries

The Finnish Parliament adopted the amended act in February 2019 (HE 243/2018). New tax rules are applied from 1 January 2020. This legal amendment contains new terminology relating to “investment funds” and “special investment funds” and their definitions. Other amendments on the conditions for granting tax-exemptions to special and other investment funds are found in the Act on income taxation (Tuloverolaki, TVL) and in the Act on the taxation of nonresidents’ income (lähdeverolaki).

The above has an impact on how comparisons are made when a foreign investment fund asks for equal treatment with a Finnish tax-exempted investment fund. For this reason, investment funds are now required to review the conditions and how they are fulfilled, under the amended provisions that control exemptions, even though the same fund had previously been issued a tax-at-source card or given a refund of tax-at-source.

For more information, see the Tax Administration’s detailed guidance On the taxation of investment funds and the provisions of section 20a of the Income Tax Act.

Tax-at-source cards for umbrella funds

An umbrella fund is a collective investment scheme that exists as a single legal entity but has several distinct sub-funds or sub-series of shares. From a legal standpoint, there is just one investment fund in existence. The entire umbrella fund is treated as being an integrated whole.

As of 1 January 2020, an “umbrella” structure is legally allowed for Finnish investment funds. The conditions on granting exemption from tax to recipients of income are evaluated at sub-fund level. You should fill out the application in the sub-fund’s name, if your reason for asking for the card is that the applicant is comparable to a Finnish tax-exempt investment fund. Add an enclosure proving that the applicant is a sub-fund belonging to an umbrella fund.

Note: If your application for the tax-at-source card is based on treaty provisions or on another reason, fill out the application in the corporate entity’s name that has been issued the certificate of residence. In this case, you must enclose information on whether the applicant is the main fund or one of the sub-funds.