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HMRC internal manual

Double Taxation Relief Manual

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DT: Finland: double taxation agreement, Article 31: Entry into force

(1) This Convention shall be ratified and the instruments of ratification shall be exchanged at Helsinki as soon as possible.

(2) The Convention shall enter into force after the expiration of thirty days following the date on which the instruments of ratification are exchanged and shall thereupon have effect:

(a) in the United Kingdom:
(i) as respects income tax (including surtax) and capital gains tax, for any year of assessment beginning on or after 6 April 1968; and
(ii) as respects corporation tax, for any financial year beginning on or after 1 April 1968;
(b) in Finland:
as respects Finnish taxes for any year of assessment beginning on or after 1 January 1969, and chargeable on the income or capital of the tax year 1968 or thereafter.
(3) Subject to the provisions of paragraph (4) of this Article the Convention between the Government of the United Kingdom and the Government of Finland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at London on 12 December 1951, as amended by the Protocol signed at London on 16 June 1966 (hereinafter referred to as ‘the 1951 Convention’), shall cease to have effect as respects taxes to which this Convention in accordance with the provisions of paragraph (2) of this Article applies.

(4) Subject to the provisions of paragraph (5) of this Article where any provision of the 1951 Convention would have afforded any greater relief from tax any such provision as aforesaid shall continue to have effect for any year of assessment or financial year or tax year beginning before the entry into force of this Convention.

(5) The provisions of sub-paragraphs (a) and (b) of paragraph (2) of this Article, of paragraph (3) of this Article and of paragraph (4) of this Article shall not apply in relation to dividends but the provisions of this Convention shall have effect, and the provisions of the 1951 Convention shall cease to be effective, in relation to dividends payable on or after the date of entry into force of this Convention.

Article 31(6) was deleted and Article 31(7) renumbered as Article 31(6) by SI 1991/2878
(6) The 1951 Convention shall terminate on the last date on which it has effect in accordance with the foregoing provisions of this Article.