The financial sector and taxation

Changes to the application of the tax treaty between Finland and Great Britain

Legal changes came into force in Great Britain recently. Starting 6 April 2025, the previous limitations to exemptions, under Article 6 of the tax treaty between Finland and Great Britain, are withdrawn. During the first months of 2025, the Tax Administration issued many tax-at-source cards to individual taxpayers receiving dividends. These cards contain a text indicating that exemptions concerning received dividends can only be granted if the distributed amount is deposited to a bank account in Great Britain. We recommend that dividend beneficiaries request a revised tax-at-source card if their existing card contains the above text.  
  
The legal changes mean that authorised intermediaries or companies distributing dividends will no longer need to make a review of whether the treaty requirements under Article 6 of the tax treaty between Finland and Great Britain are fulfilled. However, before granting exemptions allowed by the treaty, the intermediary or company should review and ensure that the dividend beneficiary's treaty country of residence is Great Britain, and that the other conditions for the exemption are fulfilled. If the dividend beneficiary's income received from Finland is not, even under the changed tax rules, deemed to be subject to tax in Great Britain, this circumstance may have an impact on the way the provisions of the tax treaty are applied. In this case, the dividend beneficiary can submit an application to the Tax Administration for a tax-at-source card.