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  • 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




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