• Service: Tax, International Tax
  • Type: Regulatory update
  • Date: 11/13/2013

Finland - Opportunity for interest on withholding tax refunds 

November 13:  Finland’s Supreme Administrative Court concluded in a September 2013 judgment that the Finnish tax administration must pay interest on refunds of withholding tax collected in contradiction to EU law.

Interest on refunded withholding taxes is applied automatically to refund requests pending before the tax administration. However, for refunds that have already been acted on by the tax administration, the taxpayer must file an appeal in order to receive interest on an already refunded amount of withholding tax. The period of limitations to file a claim for interest is five calendar years from the date of the refund decision.

The interest rate applicable to withholding tax refunds varies annually. In the years 2006 to 2013, the interest rates ranged between 0.5% and 2.5%.

Because the Supreme Administrative Court only issued the decision in September 2013, the Finnish tax administration has not yet issued guidelines as to how interest is to be calculated—in other words, what would be the applicable interest period.

KPMG observation

Luxembourg funds and others that have filed refund claims for withholding tax with the Finnish tax administration. For tax refunds that have already been refunded, it may be appropriate to file a request for interest on already refunded withholding tax.

Read a November 2013 report [PDF 93 KB] prepared by the KPMG member firm in Luxembourg: Claiming interest on already paid WHT refunds in Finland

©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International.

KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.

The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Direct comments, including requests for subscriptions, to
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.


Share this

Share this


Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)

Already a Subscriber? Login

Not a member? Subscribe now