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FinlandVero

Foreign funds must state exact holder count in withholding-card filings

Refund form 6164 adds a foreign-estate track, tests payer listed status at the dividend decision date and routes pass-through income to form 6163; card example years roll to 2027.

By Taxxa AI OyPublished 27 October 2026

Tax

Industry: Trusts, funds and similar financial entities

Foreign entities seeking a Finnish withholding card for dividend, interest or royalty income must document fund equivalenceVero with the exact number of direct unit-holders at the time of applicationVero, reporting separately the holders behind nominee registration. Where the applicant cannot supply the exact figure, the application must explain how compliance with the 30-holder requirementVero has been verified, state which documents and data were used for that verification, and enclose copies of those documents.Vero The identification field must not carry the fund manager's identifier; the applicant gives its home-state tax identifier or another official registration number, with a free-form explanation where no home-state identifier exists.

Special investment funds disclose more: whether unit-holders are professional investors or comparable wealthy individuals, the amount of fund capital, and any statutory duty to distribute annual profits. Open-ended funds state how and how often units can be subscribed and redeemed, to whom units are offered, and how investment takes place. Umbrella structures file at sub-fund levelVero: an applicant seeking equivalence with a Finnish tax-exempt investment or special investment fund applies in the sub-fund's name and attaches a separate statement confirming sub-fund status, while treaty-based or other-basis claims are filed in the name of the entity holding the residence certificate.

For individuals claiming refunds on form 6164, the payer's listed status is tested at the dividend decision date rather than the payment dateVero. Fields 3.2-3.6 cover partnerships (yhtymä) only: income received through a foreign pass-through entity is claimed in that entity's name on form 6163, while partnership income is claimed in the partner's name with the partnership details in fields 3.5-3.6. The payer's name is entered as written on the payment receipt or statement under its official Finnish name. Amounts go in their reserved boxes as euro and cents with two decimals and without commas or periods, and further dividend batches go on attachment form 6167 with their payment years recorded on the main form.

An estate section allocates the claimant: income of the year of death is claimed on form 6164Vero because a foreign estate is taxed as the deceased was during that year, while income from the following year onward is claimed on form 6163Vero because the estate counts as an entity under domestic rules. The application encloses a death certificate or a free-form account of the year of death, a proxy signed by every estate party, and the estate inventory naming the parties. Where no estate arises under the deceased's home-country private law, the heir files in the heir's own name.

Refund mechanics stand: the claim must reach Verohallinto within three years of the end of the calendar year of withholdingVero, and refunds are paid where they total at least 10 euroVero. Treaty withholding is generally credited in the residence state; EEA residents who exceptionally cannot obtain full credit may claim taxation equivalent to a generally liable person by selecting the other-basis option and attaching form 6161. One card application covers one income type, cards are generally issued for the current calendar year so applications for the current year should arrive by mid-NovemberVero, no card is issued retroactively for a prior yearVero, and no card is needed to process a refund claimVero.

The filing duties follow forms 6164/6167 and 6211, fund equivalence under Tuloverolaki 20 a §, and the applicable verosopimus.

Route each claim to its form — death-year estate income on form 6164, later estate and pass-through income on form 6163, entity cards on form 6211 — with the exact holder count or 30-holder verification and the certificates each track requires

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