Form descriptions – Relief at source and quick refund – Finnish equities
The following is a list of information regarding the various tax forms to be completed in order to benefit from relief at source of withholding tax on dividends from Finnish dividends. The templates of the forms are available in our Tax forms to use section.
One-time certificate
The one-time certificate (various versions depending on the status of the Clearstream client) must be completed and signed by the Clearstream Banking client and remains valid until revoked.
Important: Clients must select one one-time certificate, either for CBL, or CBF, as applicable for their account, meaning:
- CBL clients are requested to provide the CBL version of the form;
- CBF clients, including those with CBF-i accounts, are requested to provide the CBF version.
Per-payment pooled tax breakdown
The per-payment pooled tax breakdown must be submitted by clients who:
- Have AI status; and
- Hold an omnibus accounts structure on behalf of beneficial owners that are eligible for different tax rates/resident in a different country than of tax residence.
The per-payment pooled tax breakdown must be provided per each country of tax residence and tax rate required (one instruction per tax rate required), via Swift formatted MT565 or Xact Web Portal message, and must include the following details:
- Client account number;
- ISIN code;
- CBL Corp ID;
- Tax rate to apply: to be included in field :92A::TAXB// for SWIFT users, or tax rate field for Xact Web Portal users;
- Country of residence for tax purposes, to be specified as follows:
- Swift users: BENODET sequence in field :94C::DOMI// country of tax residence in ISO format, and in field :95V::OWND// country and “beneficial owners”, for example: “German beneficial owners; or
- Xact Web Portal users: in the beneficial owner details sequence under “benfplace”;
- Holding for which the reduced/ exempt tax rate applies.
Important note: It is mandatory to send per-payment instructions in the format stated above. Per-payment instructions sent via the “BO Upload” or other format will be rejected.
Per-payment request for quick refund
The per-payment request for quick refund, must be provided per each country of tax residence and tax rate required, via Swift formatted MT568, Xact Web Portal message and must include the following details:
- Request for quick refund
- Client account number;
- ISIN code;
- CBL Corp ID;
- Tax rate to apply: to be included in field :92A::TAXB// for SWIFT users or tax rate field for Xact Web Portal users),
- Country of residence for tax purposes, to be specified as follows:
- Swift users: BENODET sequence in field 94C::DOMI//country of tax residence in ISO format, and in field :95V::OWND//country and “beneficial owners”, for example: “German beneficial owners; or
- Xact Web Portal users: in the beneficial owner details sequence under “benfplace”);
- Holding for which the reduced/exempt tax rate applies.
ISD-E form
The Clearstream Banking version of the ISD-E form (entities) must be provided by clients holding own assets. It must be completed and signed by the final beneficial owner, confirming its status and country of tax residence.
The ISD-E form must in addition be provided to Clearstream Banking in original and remain valid for either:
- Five years from the end of the calendar year in which it is signed and dated by the Investor; or
- Until further notice, if the Investor is a government or international organisation.
Certificate of residence
The Certificate of Residence (COR) must be provided by beneficial owners requesting a reduced tax rate/ full tax exemption, according to either the “special” or “direct investment” articles of the DTT. The COR must be provided in original and must fulfil the below requirements:
- Be issued by the beneficial owner’s local tax authority;
- Include the beneficial owner’s full name, full address and country of tax residence;
- Include the Tax Identification Number (TIN);
- Confirm that the beneficial owner is resident in accordance with the relevant DTT with Finland;
- Confirm that the DTT eligibility requirements for special rates/tax exemption are met by specifying the relevant DTT article under which the beneficial owner qualifies for the “special” or “direct investment” articles of the DTT.
- The COR must cover the payment date and remains valid until there is a change in circumstances.
Tax-at-source card
The tax-at-source card must be provided for beneficial owners that are eligible for full tax exemption (0%) under domestic law.
It must be issued by the FTA, confirm that the beneficiary is eligible for tax exemption on Finnish dividend payments and be valid for the pay date with respect to all income for which such exemption is claimed
Per-payment beneficial owner declaration
The per-payment beneficial owner declaration must be provided by clients holding own assets in the event where the DTT rate requested is less than 15% and the dividend gross amount, received from one single dividend payer per payment, is EUR 10.000,00 or more.
It must be provided by the beneficial owner at the time of the relevant dividend payment in the form of a Swift (formatted MT565 message) or Xact Web Portal message and state the following:
“Att. Tax Operations
Clearstream Banking account: XXXXX (the “Account”)
ISIN: FIXXXXXXXXXX
Payment date: XX.XX.XXXX
Per-payment declaration for dividend payments received from Finnish publicly listed equities with DTTrates below 15%
For the purpose of ensuring that relief at source (or quick refund) from Finnish withholding tax is granted on the above dividend payment, paid to our Account, with a withholding tax rate below 15%, we hereby certify that we:
Name of beneficial owner (full name): XXXX
Tax residence of beneficial owner (full address): XXXX
Tax identification number of the beneficial owner (local TIN): XXXX
• have not bought the shares less than 30 days before the record date; and
• are the final economic beneficial owner of the Finnish dividend payment related to the ISINFIXXXXXXXXXX and paid to our Account on VD XX/XX/XXXX, and that our entitlement to such dividendpayment is not restricted by any contractual obligations (such as lending and borrowingarrangements) which would require that the dividend paid to us is transferred further to an actualinvestor; and
• are entitled to the application of withholding tax at the reduced tax rate of XX% in accordance withthe DTT concluded between Finland and our country of tax residence.
This per-payment declaration complements the “One-Time Certificate for Finnish publicly listed equities - own assets” dated XX.XX.XXXX.”
Direct investment confirmation
The confirmation must be provided by beneficial owners requesting full tax exemption, under the “direct investment” articles of the DTT. The confirmation must be provided per payment in original and must fulfil the below requirements:
- Be issued by the issuing company;
- Confirm that on record date the beneficial owner meets the conditions for exemption under the “direct investment” articles (such as holding 10% of the capital of the company distributing the dividends).
Parent-subsidiary confirmation
The confirmation must be provided by beneficial owners requesting full tax exemption, according to the Parent-Subsidiary regime. The confirmation must be provided per payment in original and must fulfil the below requirements:
- Be issued by the issuing company;
- Confirm that on record date the beneficial owner held a substantial holding in the company (at least 10% of the capital of the company distributing the dividends);
- Confirm that the beneficial owner/ company takes one of the forms listed in the Annex I, Part A of the Directive; and
- Confirm the beneficiary's country of residence is in the European Economic Area (EEA).