The Finnish tax authorities announced their intention to track and potentially audit situations where no dividend withholding tax is operated due to dividend stripping arrangements including stock lending. Under Finnish law as it currently stands, the withholding agent is allowed to apply the dividend withholding tax rate under an applicable treaty at the time of distribution (as opposed to a post-fact reclaim) based on either (i) a "tax card" issued by the tax authorities for the relevant case, or failing that (ii) on the information supplied by the non-resident recipient of dividends. There is no requirement under the law for...