Application for Refund of Finnish Withholding Tax on Dividends, Interest, and Royalties (Non-individual applicants, e.g. a corporate entity), how to fill out the form - Forms 6163e and Enclosure 6167e
The guidance on these pages concerns Form 6163e and Form 6167e – the enclosure. See the final part of this guidance for specific instructions on how to fill in Form 6167e.
Choosing the right form
These instructions refer to application form 6163e and its enclosure form 6167e. Specific instructions for the enclosure 6167e can be found towards the end of this page.
- Form 6163e is designed for corporate applicants making a request for refund of Finnish tax withheld at source on the dividends, interest or royalties that the corporate entity has received.
- If the applicant is a natural person (an individual applicant), complete and submit Form 6164e instead.
- However, Form 6167e can be enclosed to both Form 6163e and 6164e.
- Neither form can be used by entities that have a permanent establishment in Finland. If the applicant has a permanent establishment, 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.
- Forms 6163e and 6167e are not intended for Finnish corporations or organisations that are applying for refund of withholding tax from abroad. To ask a foreign tax authority to pay a refund to your corporation, submit an application to the country that withheld the tax at source.
Applications for refund 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.
Fill in all relevant fields and add enclosures
Do not forget to complete the fields of the form that are relevant to your circumstances.
Select the language of the form depending on which language the decision and requests for further information you may receive should be in:
Enter all amounts of money in the euro currency. The decision on refunding will be made out in the euro currency, as well.
The following enclosures are required:
- the documents listed on the form that you should enclose
- proof that the person who signed the application or power of attorney is authorised to do so
- a dividend voucher or receipt. The Tax Administration may ask you to present a full audit trail from the first payor to the final beneficiary.
If you believe the applicant is comparable to a Finnish tax-exempted organisation, and this is the basis for your request for refund, enclose the following documents:
- Explanation of circumstances making it possible to compare the applicant with a tax-exempted Finnish organisation
- Form 6161e (Certificate of tax treatment concerning dividends) or other documentation, issued by the country of residence, establishing that the residence country cannot fully give credit for the Finnish tax at source.
You may apply for a refund during the three calendar years that follow the year of payment and withholding. If excess withholding only amounts to €10 per year or less, we will not pay a refund.
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. For example, fill in your street address, postal code and post office in the separate fields provided on the form. 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, including the Southern Finland Corporate Tax Office, Registry, Vääksyntie 4, 00510 Helsinki.
How to complete Form 6163e
1 Applicant (income beneficiary)
The first section is for information about applicant, i.e. the beneficial owner of the dividends, interest or royalties.
1.1 Applicant’s official name
No other party than the beneficial owner can be the applicant (for more information, see section 7: Share lending and beneficial owner). Enter the name of the applicant, 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 Accounting period (necessary for the interest calculation)
Fill in the start and end dates of the applicant's accounting period when the amounts were paid to the applicant. If you are filing an application in respect of dividends paid and received during several accounting periods, only fill in one accounting period on this form, giving details on the dividends within it. Then complete Form 6167e to enclose, and give the details on the dividends paid to the applicant during the other periods. Use as many separate Forms 6167e to show each period.
Example 1: Accounting period start date is April 1, end date March 31. The applicant was paid dividends 29 March 2018. Fill in 01.04.2017 and 31.03.2018 in the two fields.
Example 2: The applicant has two accounting periods ending during the calendar year. The first one of them is 1 April 2017 – 31 March 2018, the other one 1 April 2018 – 31 December 2018. The applicant was paid dividends first on 15 March 2018, then on 1 May 2018. It is important that you indicate a clear separation between the two periods. Complete Form 6163e with start and end dates 01.04.2017 to 31.03.2018, filling in the specific details on the dividends received 15 March 2018 in fields 5.9 to 5.15. Complete Form 6167e, the enclosure, with start and end dates 01.04.2018 to 31.12.2018, instead. Then specify the dividends received 1 May 2018.
1.4–1.6 Postal address
If an agent or representative is not submitting the application (see section 2), the address you fill in here will be the one that the Tax Administration uses for sending you the refund decision and any letters 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.
1.9–1.10 Country of residence
Fill in the country code. Please note that the country of residence of a non-resident taxpayer cannot be Finland (FI).
Use the ISO 3166 standard country code.
Country codes can also be found on the list of Tax treaties that Finland has signed with other countries. However, that page only contains the countries that have a tax treaty with Finland.
1.11–1.13 Tax identification number (TIN) in the residence country
The applicant’s Tax Identification Number is required information. If the country of residence has not issued a TIN to the applicant, enclose a written account explaining this, and fill in some other identity code in field 1.12. Enter a code that has been issued by the country of residence. You can leave field 1.13 blank if no Finnish Business ID has been issued to the applicant.
1.14–1.15 Legal entity form of the applicant
Tick the appropriate box in 1.14. Add a further description of the applicant's legal form as necessary in 1.15, giving details of its type of incorporation in the circumstances that prevail in the country of residence. If none of the suggested legal forms is correct, tick “Other”. In this case, you must add a further description in 1.15.
Example 1: The applicant is a limited-liability company. Tick “1 Corporate entity” under 1.14, and enter "Limited-liability company" in 1.15 as a description.
Example 2: The applicant is an investment fund. Tick “5 UCITS collective investment scheme (fund)”, or tick “6 Non-UCITS fund”. Enter e.g. "an investment fund with variable capital" as a description in field 1.15.
1.16–1.17 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 in 1.16 as appropriate, depending on whether the applicant was listed or not listed at the time when the dividends were paid. Enter the applicant’s ISIN code in field 1.17. Leave blank if the applicant has no ISIN code.
1.18 Umbrella funds
If the corporate entity being the applicant is part of an entity known as “umbrella fund”, indicate whether it is the main fund or a sub-fund. If the applicant is the main fund, enclose a list of sub-funds. Tick the appropriate box. In addition to the above, it is required that the vouchers you enclose for proving the dividend payments contain the names of the sub-funds that have been the recipients. If, instead, the corporate entity, the applicant, is a sub-fund, you must fill in the main fund’s name and its Tax Identification Number.
For more information, see guidance below under “Umbrella funds”.
1.19–1.21 Information on previous refunds
Tick “Yes" in 1.19 if the applicant has submitted a refund application to the Tax Administration previously. If, for at least one item of income, the applicant has asked the payer to give a refund (in order to adjust the amount withheld during the year of payment), tick “Yes" in 1.20.
Tick “Yes" in 1.21 if the applicant has submitted, for at least one item of income, a refund application to the Tax Administration previously.
Fill in the registration codes or decision numbers in field 1.24 if the Tax Administration has issued any refund decisions to the applicant in response to the applicant’s applications in the past.
1.22 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, and income is attributable to that permanent establishment, the income and the taxes withheld at source on it must be reported on Form 6U, the income tax return. Further information on permanent establishments in income taxation.
1.23 Refund of the tax withheld at source is seeked on the basis of:
If reference to the tax treaty between Finland and applicant’s country of tax residence is made, tick “based on tax treaty between Finland and applicant’s country of residence”. It must be clearly stated on the applicant’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 reference is made 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 “EU Law”. If the application is based on a Directive of the EU, tick the “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 your reasoning for requesting a refund of tax at source.
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. The letter of authorisation (power of attorney) must be enclosed. It must be authorised with the signature of someone who has the right to sign for the corporate entity being the applicant.
Field 2.2 “Representative’s Business ID” is not a required field. However, it serves the purpose of creating a list of all the refund applications from one agent/representative over time. In addition, the Business ID may facilitate any checking of the stages of processing after an application has been submitted. The ID 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 Bank account number for the refund
This section is for the bank account where the applicant asks for the refund to be transferred to.
If you are within the Single European Payment Area (SEPA), fill in the account holder’s name, the IBAN bank account number, and the bank’s BIC code.
For bank accounts outside of the SEPA, write down the name of the account holder, the bank account number, the clearing code, and the name and address of the bank.
You can add a “reference no. for facilitating the payment” – the Tax Administration will include it in the bank transfer information when sending the refund. Such a reference number is helpful when the refund has arrived and it must be identified as a Finnish Tax Administration’s refund when it shows on the bank account statement.
4 Information on the income
This section is for specifying the category: dividend, interest or royalty income. Tick the appropriate box under field 4. If your application concerns taxes withheld at source from a payment of dividends, move on to Section 5 after ticking the “dividends” box. If it concerns interest payments or royalties, move on to Section 6. If it concerns a refund of corporate capital to shareholders, tick “dividends” and enclose a free-text account giving details on how you received such a refund.
5.1 Receipt of dividends is...
Tick the box as appropriate, indicating whether the received dividends were due on the applicant’s direct shareholding or due on nominee-registered shares. Move on to field 5.7.
5.2–5.6 Information about the fund or partnership
If the dividends were paid through an investment fund or a partnership, tick the box as appropriate and give the necessary details on lines 5.2 to 5.6. If any changes have been made to the name of the fund or partnership, please give the old and the current names. Write up and enclose an account explaining the applicant’s share of ownership in the fund or partnership.
Example 1: The applicant is a unit holder in an Austrian investment fund. In accordance with Austrian legislation, the fund is regarded as a flow-through unit. The applicant, i.e. the unit holder, is considered to be the beneficial owner of the dividends, not the flow-through investment fund. Tick the “through a fund” box and give details on the investment fund on lines 5.2 to 5.6.
Example 2: The applicant is a shareholder in a limited partnership (LP) in the United States. If the applicant received the dividends by way of this partnership entity, tick 5.1 “through a partnership” and complete fields 5.2–5.6 with the required information. If, instead, the applicant is the LP, enclose a list of its shareholders.
5.7–5.9 Information about the payer (of the income)
Please spell the payer's name exactly as it is spelled in the dividend voucher, bank statement, other documentation. If the payer is a listed company, fill in its ISIN code in field 5.8. The ISIN code is necessary because it helps identify the payer. If the payer is a non-listed corporate entity, fill in the payer’s Business ID in addition to its name in field 5.7 (if the Business ID is known to you).
5.10–5.14 Information on the dividend payment
Enter the received dividends in the euro currency. If there were several payments, complete Form 6167e and enclose it with your application. One Form 6167e is designed for information relating to just one accounting period. Use as many Forms 6167e as you need. Please note that you should not repeat the information on Form 6167e if you have already entered the amount of the dividends that were paid (on Form 6163e i.e. the main form).
When filling in field 5.10, please note that the date of payment refers to the date set out by the distributing company, at its Annual General Meeting, as the date when the dividends are to be paid. In other words, the date of payment that you should enter in field 5.10 is not the date when the amount arrives in the beneficiary’s bank account.
You are required to enter how many shares you have in 5.11, and then enter the gross amount of your dividends, how much tax was withheld on them originally, and how much you demand to be refunded back to you in fields 5.12, 5.13 and 5.14. Even if you have already received some restitution of the withheld amount back, you should still fill in the entire tax that was originally withheld in field 5.13.
Example: 30% tax at source on the item of income was withheld at source. The exact amount was €1,000. However, the payer had made an adjustment of the tax withheld at source already before the calendar year of payment ended: the payer paid €500 back to the applicant. The applicant is now requesting that the Tax Administration pay a refund of the remaining tax at source (€500 equalling 15% of the income). Accordingly, you should enter €1,000 as the “amount of tax withheld” and €500 as the “amount requested as refund”.
5.15–5.17 The amount requested as refund in total
These fields are for the sum total of all the received dividends that relate to your refund request. This means that you must enter the total gross dividends, how much was withheld on them as tax at source, how much you believe should be refunded, according to what you have specified and itemised on Form 6163e and Form 6167e. The fields 5.15–5.17 and 5.12–5.14 should have exactly the same values if your refund application only concerns one single dividend distribution.
Example 1: The applicant filled out Form 6163e, informing of the following dividends from the “A” company: €1,000 as the gross amount, with €300 withheld at source, amount of tax requested for refund – €150. The applicant also filled out Form 6167e as the enclosure, informing of dividends from company “B”: €500 as the gross amount, with €150 withheld at source, amount of tax requested for refund – €75. Fields 5.15–5.17 of Form 6163e must in this case be completed as follows: €1,500 as the combined gross amount, with €450 withheld at source, amount of tax requested for refund – €225.
Example 2: The applicant only asks for refund for the dividends from “A”. Fields 5.12–5.14 of Form 6163e must in this case be completed as follows: €1,000 as the gross amount, with €300 withheld at source, amount of tax requested for refund – €150. The applicant must indicate exactly the same amounts in 5.15–5.17: €1,000 as the gross amount, with €300 withheld at source, amount of tax requested for refund – €150.
5.18 Give the name of the foreign intermediary bank(s) handling the dividend payment
Give the names of all the banks that were involved in the transfer of the payment to the beneficial owner i.e. the applicant. Enclose an additional free-text account if many intermediary banks were involved. The chains of custodians, specifically for each transaction of dividend payment, should be cleared up.
Example: The “C” bank transfers a dividend amount to the beneficial owner, i.e. to the applicant. “C” had received the amount from bank “B”, an account operator in a foreign country. “B” had received the amount from the Finnish account operator, bank “A”, that pays out the dividends on the distributing company’s behalf. You must fill in field 5.18 with the names of all the intermediary banks. The names of Bank A, Bank B and Bank C must be filled in.
5.19 Preparing an enclosure on Form 6167e
Full details must be filed for each payment. If the dividends were paid in several payments, fill in and enclose Form 6167e. Specific guidance for Form 6167e is in the final passages below. Do not use other forms than Forms 6163e and 6167e for reporting.
6 Interest payments or Royalties
This section is for applicants that received income in the form of interest or royalties, not dividends. When filling in this section, you should apply the instructions for fields 5.7–5.14 to provide information on the interest and royalties accordingly.
7 Share lending and beneficial owner
Tick boxes 7.1–7.4 as appropriate, taking into consideration the category of income and the applicant’s circumstances.
You must tick “Yes” in field 7.1 if the applicant is the actual beneficiary, i.e. the beneficial owner, and the shares are not part of any contractual 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 were lent/borrowed, or if some other arrangement concerns them, you must tick “Yes” in fields 7.2–7.3. If you answered “Yes” to either 7.2 or 7.3, 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.
If you answered “No” to 7.4, please enclose a document giving the reasons for refunding the withheld tax at source to the applicant.
If you are not sure of the above facts and circumstances, you can leave these fields blank.
Interest payments or royalties
You must tick “Yes” in field 7.1 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 interest specified in the application. Fields 7.2–7.4 may be left blank.
Certificate of residence
One of the required enclosures is a certificate of residence, expressly issued to the applicant. Tick the correct box if the issuer of the certificate of residence is a tax authority. 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 certificate of residence was issued.
Power of attorney and the right to sign for the applicant
Tick the box at the bottom if the applicant has given their Power of Attorney to the agent or representative. Enclose the letter of authorisation (power of attorney). In addition, enclose documentation – an excerpt from the trade register, a photocopy of company charter, etc. – proving that the person who signed the letter or the application has the right to sign for the corporate entity.
Further instructions for special circumstances
An “umbrella” fund is an investment fund that consists of several sub-funds. The sub-funds are seen as being part of the main fund, the umbrella. From a legal standpoint, there is just one investment fund in existence.
As the umbrella fund is seen as a single legal entity, any refunds of Finnish withholding tax are refunded to the main fund. This means that the refund application should also be submitted in the name of the main fund. In addition, you should attach a separate document showing which dividends were paid to each individual sub-fund. If chains of custodians (intermediaries) differ between sub-funds, you should attach a document containing information on such differing chains.
If, on the other hand, you wish to receive the refund decisions per sub-fund, please submit your applications per sub-fund, as well – identifying the sub-fund that each application is related to. However, you must write out the application in the name of the main fund also when you have multiple sub-funds. Attach a free-form enclosure identifying which dividends, received by which sub-fund, the application is related to.
Note: In certain countries, sub-funds can be separate tax subjects and can obtain a certificate of residence in their own name. In this case, please submit the refund application in the name of the sub-fund and fill in all details from the perspective of the sub-fund.
Pension providers and life insurance companies
If the applicant is a foreign pension provider or a foreign life insurance company, fill in all the other details on Form 6163e except fields 5.7 through 5.14 (information on dividends received). Instead, enter the total refund, after deductions, that you request in field 5.17. Do not enclose Form 6167e in this case. Instead, provide a breakdown of all your items of income and the taxes withheld at source. Enclose it with the application. Provide a breakdown of the deductions and their reasons. See the guidance: Taxation of dividends received by foreign entities offering statutory pension insurance.
In any case, do not forget to fill in field 5.18 regarding the intermediary banks that have handled the transfer of money. If more than one custodial chains (consisting of intermediaries, banks) are involved, you can provide a free-text enclosure containing further descriptions on the chains.
Depositary receipts (such as ADR)
Securities known as “depositary receipts” are considered independent, standalone securities as they provide their holder a right to hold shares in accordance with a specified value or “ratio”. Trading with depositary receipts goes on in a market in the same way as with corporate stock. For example, American Depositary Receipts (ADR) are stock-exchange traded in the United States (e.g. at AMEX, NYSE and Nasdaq).
If your application concerns dividends that were received on the basis of a depositary receipt, please add further information to your application on a free-form enclosure. You must additionally enclose a voucher or receipt proving that the dividends were paid. The voucher/receipt should be addressed to the party that holds the depositary receipt. Please note that the Tax Administration pays out the refunds in euros only, regardless of the foreign currency that the dividends had been received in.
How to complete Form 6167e (the enclosure)
1 Applicant (beneficial owner)
1.1 Official name
Give the applicant's name spelling it in the same way as it was on the main application Form 6163e.
1.2 Tax identification number in country of residence (TIN)
Give the applicant's TIN or other registration number in the same way as it was on the main application Form 6163e.
1.3–1.4 Applicant’s accounting period
Give the start and end dates of the applicant's financial year (= accounting period) when the dividends were paid to the applicant. When filling out the form, you should only include the dividends paid between the above start and end dates. If your refund application concerns dividends paid and received during several accounting periods, only fill in one accounting period on Form 6163e, giving details on the payments made within this period. Then complete a Form 6167e to show each one of the other accounting periods or years. Use as many Forms 6167e as you need.
Example 1: Payments of dividends were made to the applicant on the 1st of May 2014, 1st of May 2015 and 3rd of May 2016. The applicant’s accounting period is the calendar year. Form 6163e must be filed, for asking for refund for the 1 May 2014 payment. Enter the start and end dates on the form as 01.01.2014 and 31.12.2014, respectively. Additionally, complete two Forms 6167e and enclose them. One of them is for the 1 May 2015 payment, and you should enter the relevant accounting period as 01.01.2015 to 31.12.2015. The other Form 6167e would show the 3 May 2016 payment, and you should enter the relevant accounting period as 01.01.2016 to 31.12.2016.
2 Specification of the dividends
Follow the same instructions as you would for 5.7 through 5.14 on Form 6163e.