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HMRC internal manual

Double Taxation Relief Manual

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DT: Finland: double taxation agreement, SI 1996 No. 3166: Exchange of Notes

 

With reference to paragraph (2) of Article 2, sub-paragraph (l)(j) of Article 3,sub-paragraph (2)(d) of Article 4, paragraphs 1, 2, 3 and 4 of Article 28 and Article 29of the Convention, it is noted that in the Convention the Finnish-language term asianomainen viranomaineni’ is used as the equivalent for the English-language term competent authority’. However, the correct equivalent in Finnish is now ‘toimivaltainen viranomainen’. It has been agreed that, in relation to the Finnish-language text as amended, the term ‘toimivaltainen viranomainen’ as used in the Protocol between the two Governments to amend the Convention, signed today, should be read in place of asianomainen viranomainen’ used heretofore in the Convention.

With reference to sub-paragraph (b) of paragraph (1) and sub-paragraph (b) of paragraph(2) of Article 25 of the Convention, by continuing to use the criterion of a holding of voting power the Contracting States are exercising the option provided in paragraph 2 of Article 3 of Council Directive 90/435/EEC of 23 July 1990 to derogate from paragraph 1 of that Article by replacing the criterion of a holding in the capital of a company of another Member State by that of a holding of voting rights.