In a recent government draft bill, the Finnish government proposes to shorten the time limitation period for all tax matters to three years, starting in tax year 2017.
The current time limitation period for tax matters in Finland, and thus also for withholding tax (WHT) reclaims, is five years starting from 1 January after the year the WHT was levied.
The amendments proposed by the Finnish government should enter into force in tax year 2017 and should apply to WHT that is levied from 2017 onwards. Based on this, the tax year 2016 would be the last year for which the current 5-year time limitation applies. In other words, the 3-year period should not apply retroactively and Finnish WHT levied in 2016 can be reclaimed until the end of 2021, whereas Finnish WHT levied in 2017 should be reclaimable until the end of 2020.
The final legislation may differ from this draft. However, it is very likely that the 3-year time limitation is going to apply from 2017 onwards.
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