Global REIT Survey 2011 - EPRA
Global REIT Survey 2011 - EPRA
Global REIT Survey 2011 - EPRA
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<strong>Global</strong> <strong>REIT</strong> <strong>Survey</strong> <strong>2011</strong>REPORTINGFinland (<strong>REIT</strong>)Gains on disposals of shares in a Finnish <strong>REIT</strong> could be subject to tax at 28%in case at least 50% of the <strong>REIT</strong>’s assets are directly held property located inFinland (as opposed to shares in mutual real estate companies), subject tothe applicable tax treaties. In practice, disposals of shares in a Finnish <strong>REIT</strong>should typically be outside the scope of Finnish capital gains tax.Withholding taxA non-resident shareholder suffers the withholding tax of 28% no matter ifcorporate or individual, subject to applicable tax treaty provisions. Treatyrelief can be claimed ex ante or retrospectively. The dividend should betreated as a dividend distribution under most treaties. EU Parent-SubsidiaryDirective not applicable.Individual shareholderA foreign <strong>REIT</strong> distribution to a Finnish individual shareholder is likely to betreated as a normal dividend from the non-resident company (will dependon structure of foreign <strong>REIT</strong>). As general rule, 70% of a dividend from a listedcompany is taxed at 28%, whereas a dividend from a non-listed company isdivided into capital income (taxed at 28%), earned income (taxed at progressiverates) and tax exempt income under a certain formula. n5 Tax treatment of foreign <strong>REIT</strong>s and itsdomestic shareholdersForeign <strong>REIT</strong> Corporate shareholder Individual shareholderTaxed under normal Finnishtax rules.A foreign <strong>REIT</strong> distribution toa Finnish shareholder is likelyto be treated as a normal dividendfrom the non-residentcompany (will depend onstructure of foreign <strong>REIT</strong>)A foreign <strong>REIT</strong> distribution toa Finnish shareholder is likelyto be treated as a normal dividendfrom the non-residentcompany (will depend onstructure of foreign <strong>REIT</strong>)Foreign <strong>REIT</strong>A foreign <strong>REIT</strong> will be taxable under normal Finnish rules.AUTHORS CONTACTFinlandCorporate shareholderA foreign <strong>REIT</strong> distribution to a Finnish corporate shareholder is likely tobe treated as a normal dividend (which may be fully or partially tax-exemptunder certain conditions) from the non-resident company (will depend onstructure of foreign <strong>REIT</strong>).Samuli MakkonenTel. + 358 9 2280 1752samuli.makkonen@fi.pwc.comPauliina LaineTel: +358 9 2280 1722pauliina.laine@fi.pwc.com« back to content page7
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