Finland: Tax documentation required for beneficial owners eligible for the Parent-Subsidiary Directive
Clearstream Banking1 would like to inform customers that effective
exemption at source, quick and standard refund on dividends from Finnish equities, through Clearstream Banking, is available for beneficial owners that are European Parent Companies (“EUPC”), provided that the beneficial owner is a company as defined in the Parent-Subsidiary Directive 90/435/EEC and owning at least 10% of the payer’s share capital on the record date of the relevant dividend payment.
Customers wishing to obtain exemption at source, quick or standard refund on behalf of beneficial owners that are eligible for exemption under the Parent Subsidiary Directive, will have to provide Clearstream Banking with the following documentation.
Exemption at source or quick refund
A One-Time Certificate for Finnish Equities
The one-time certificate must be completed by the Clearstream customer and remains valid until revoked; and
A List of Beneficial Owners – Finnish equities
If the Clearstream Banking customer is not the sole beneficial owner of the Finnish equities in the account, a list of beneficial owners must be uploaded electronically via Clearstream Banking's Online BO Upload facility.
and in addition:
A confirmation of holdings from the issuing company
The confirmation must:
- be issued and signed by the issuing company;
- confirm the beneficial owner’s holding on record date;
- confirm that the beneficial owner held substantial holding in the company and is eligibility for the EEC parent subsidiary directive;
- be provided as a copy;
- be provided on a per payment basis; and
A certificate of residence (COR)
The certificate of residence must:
- be issued by the beneficial owner’s local tax authority;
- include the beneficial owner’s full name and address;
- be provided in original and must be issued and dated prior to the relevant record date.
The COR remains valid for one calendar year and must be renewed on an annual basis;
A “Tax at source card”
Beneficial owners that are eligible for exemption under the Parent Subsidiary Directive, may opt to provide a “Tax at source card”, instead of the “confirmation of holdings from the issuing company “and “COR”. In such case the “Tax at source card” must:
- be issued and signed by the Finnish Tax Authorities (FTA);
- confirm that “direct investment graded tax rate” is applicable for the beneficial owner;
- confirm the period for which it is applicable;
- be provided as a copy.
The “Tax at source card” remains valid for the period stated by the FTA.
The One-Time Certificate for Finnish Equities is available as follows:
- One version for customers of Clearstream Banking S.A (CBL); and
- One version for customers of Clearstream Banking AG (CBF). This includes CBF customers having 6-series accounts via the Creation platform.
Customers are consequently requested to complete the certification (either CBL or CBF version), for their account as applicable.
Exemption at source
Documentation to obtain exemption at source from withholding tax on dividends from Finnish equities must be received by Clearstream Banking no later than four business days before the first payment date by 18:00 CET.
The quick refund procedure can be applied for between 1 June and 1 November of the year of the dividend payment.
Customers wishing to submit standard refund applications, via Clearstream Banking, for beneficial owners that are eligible for exemption under the Parent Subsidiary Directive, are requested to provide the following documentation, in addition to the normal reclaim documentation, which is stated in the Finnish Tax Guide:
A form VEROHe 6162
The form VEROH 6162e is required to confirm the validity of the direct investment and must be provided in original per reclaim application.
For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.