References/10 May 2024

Borenius successfully represented a consortium of leading Finnish issuers in a landmark withholding tax dispute

Our Tax team successfully represented a consortium of Finnish listed companies before the Helsinki Administrative Court on a case regarding the obligations of dividend payors and the withholding tax treatment of dividends paid to a foreign financial institution engaged in share lending.

The consortium included all major Finnish companies listed on the Helsinki Stock Exchange.

As a result of the court proceedings, the appeal made by the Finnish State Representative was dismissed, and the Administrative Court ruled that the Finnish listed companies had acted in accordance with applicable law and that no withholding taxes should be imposed on them.

This landmark dispute is the first Finnish court case on this topic, and the positive ruling Borenius secured for the consortium is significant as it sets boundaries on the extent of the investigation obligations required from Finnish dividend payers in cross-border situations. The ruling is also important because it addresses the highly controversial concept of beneficial ownership.

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Einari Karhu



Anna Tallgren



Mikko Vesikivi

Senior Associate