Finland Tax Agency Clarifies Dividend Taxation for German Alternative Investment Funds

March 18, 2026, 5:00 AM UTC

The Finnish Tax Administration March 12 posted online Central Tax Board Preliminary Decision No. KVL:2026/6, clarifying dividend taxation for German alternative investment funds (AIFs). The taxpayer, a German AIF, met the definition of an AIF under the EU AIFM Directive, had fewer than 30 unitholders, and received Finnish dividends. The taxpayer inquired whether it was a special investment fund under the Finnish Income Tax Act that qualified for exemption from withholding on dividends. The Central Tax Board held that: 1) the German legislation’s intent didn’t correspond to the Act’s objective to limit the tax deferral of unitholders of limited holding, ...

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