
1 
This Order may be cited as the 
Double Taxation Relief (Taxes on Income) (Finland) Order 1970.

2 
It is hereby declared—
(a) that the arrangements specified in the
Convention set out in the Schedule to this Order have been made with the Government
of the Republic of Finland with a view to affording relief from double taxation
in relation to income tax, corporation tax or capital gains tax and taxes
of a similar character imposed by the laws of Finland; and
(b) that it is expedient that those arrangements
should have effect.
W.G. Agnew
For the Government of the United Kingdom of Great Britain and
Northern Ireland:
MICHAEL STEWART
For the Government of the Republic of Finland:
AHTI KARJALAINEN

SCHEDULE



CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND
NORTHERN IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF FINLAND FOR THE AVOIDANCE
OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES
ON INCOME AND CAPITAL 
The Government of the United Kingdom
of Great Britain and Northern Ireland and the Government of the Republic of
Finland; 
Desiring to conclude a new Convention for
the avoidance of double taxation and the prevention of fiscal evasion with
respect to taxes on income and capital; 
Have agreed
as follows:— 

ARTICLE 1 

This Convention shall apply to persons who are residents of one or both of
the Contracting States.

ARTICLE 2 

(1) The taxes which are the subject of this
Convention are:
(a) in the United Kingdom of Great Britain
and Northern Ireland:
(i) the income tax (including surtax);
(ii) the corporation tax; and
(iii) the capital gains tax;
(b) in Finland:
(i) the State income and capital tax;
(ii) the communal tax;
(iii) the church tax; and
(iv) the sailors' tax.
(2) This Convention shall also apply to any
identical or substantially similar taxes which are imposed in either Contracting
State after the date of signature of this Convention in addition to, or in
place of, the existing taxes. The competent authorities of the Contracting
States shall notify to each other any changes which are made in their respective
taxation laws.

ARTICLE 3 

(1) In this Convention, unless the context
otherwise requires:
(a) the term “United
Kingdom” means Great Britain and
Northern Ireland, including any area outside the territorial sea of the United
Kingdom which in accordance with international law has been or may hereafter
be designated, under the laws of the United Kingdom concerning the Continental
Shelf, as an area within which the rights of the United Kingdom with respect
to the sea bed and sub-soil and their natural resources may be exercised;

(b) the term “Finland”
 means the Republic of Finland, including
any area outside the territorial sea of Finland within which in accordance
with international law and under the laws of Finland concerning the Continental
Shelf the rights of Finland with respect to the sea bed and sub-soil and their
natural resources may be exercised;
(c) the term “nationals”
 means : 
(i) 
in relation to the United Kingdom, all citizens of the United Kingdom and
Colonies who derive their status as such from their connection with the United
Kingdom and all legal persons, partnerships and associations deriving their
status as such from the law in force in the United Kingdom;

(ii) in relation to Finland, all
individuals possessing the nationality of Finland and all legal persons, partnerships,
associations and other entities deriving their status as such from the law
in force in Finland;
(d) the term “United
Kingdom tax” means tax imposed
in the United Kingdom being tax to which this Convention applies by virtue
of the provisions of Article 2;
 the term “Finnish tax”
 means tax imposed in Finland being tax
to which this Convention applies by virtue of the provisions of 
Article 2;
(e) the term “tax”
 means United Kingdom tax or Finnish
tax, as the context requires;
(f) the terms 
“a Contracting State” and 
“the other Contracting State” mean the United Kingdom or Finland, as the context requires;

(g) the term “person” comprises
an individual, a company and any other body of persons;
(h) the term “company”
 means any body corporate or any entity
which is treated as a body corporate for tax purposes;
(i) the terms 
“enterprise of a Contracting State” and “enterprise of the other Contracting State”
mean respectively an enterprise carried on by a resident
of a Contracting State and an enterprise carried on by a resident of the other
Contracting State;
(j) the term “competent
authority” means, in the case of
the United Kingdom, the Commissioners of Inland Revenue or their authorised
representative, and in the case of Finland, the Ministry of Finance or its
authorised representative.
(2) As regards the application of this Convention
by a Contracting State any term not otherwise defined shall, unless the context
otherwise requires, have the meaning which it has under the laws of that Contracting
State relating to the taxes which are the subject of this Convention.

ARTICLE 4 

(1) For the purposes of this Convention,
the term “resident of a Contracting State”
 means, subject to the provisions of 
paragraphs (2) and (3)
of this Article, any person who, under the law of that State, is liable to
taxation therein by reason of his domicile, residence, place of management
or any other criterion of a similar nature; the term does not include any
individual who is liable to tax in that Contracting State only if he derives
income from sources therein. The terms 
“resident of the United Kingdom” and “resident of Finland” 
shall be construed accordingly.
(2) Where by reason of the provisions of 
paragraph (1) of this Article an individual
is a resident of both Contracting States, then his status shall be determined
in accordance with the following rules:
(a) he shall be deemed to be a resident of
the Contracting State in which he has a permanent home available to him. If
he has a permanent home available to him in both Contracting States, he shall
be deemed to be a resident of the Contracting State with which his personal
and economic relations are closest (centre of vital interests);
(b) if the Contracting State in which he
has his centre of vital interests cannot be determined, or if he has not a
permanent home available to him in either Contracting State, he shall be deemed
to be a resident of the Contracting State in which he has an habitual abode;

(c) if he has an habitual abode in both Contracting
States or in neither of them, he shall be deemed to be a resident of the Contracting
State of which he is a national;
(d) if he is a national of both Contracting
States or of neither of them, the competent authorities of the Contracting
States shall settle the question by mutual agreement.
(3) Where by reason of the provisions of 
paragraph (1) of this Article a person other
than an individual is a resident of both Contracting States, then it shall
be deemed to be a resident of the Contracting State in which its place of
effective management is situated.

ARTICLE 5 

(1) For the purposes of this Convention,
the term “permanent establishment”
means a fixed place of business in which the business
of the enterprise is wholly or partly carried on.
(2) The term “permanent
establishment” shall include especially: 
(a) a place of management;

(b) a branch;

(c) an office;

(d) a factory;

(e) a workshop;

(f) a mine, quarry or other place
of extraction of natural resources;

(g) a building site or construction
or assembly project which exists for more than twelve months
.
(3) The term “permanent establishment”
 shall not be deemed to include:
(a) the use of facilities solely for the
purpose of storage, display or delivery of goods or merchandise belonging
to the enterprise;
(b) the maintenance of a stock of goods or
merchandise belonging to the enterprise solely for the purpose of storage,
display or delivery;
(c) the maintenance of a stock of goods or
merchandise belonging to the enterprise solely for the purpose of processing
by another enterprise;
(d) the maintenance of a fixed place of business
solely for the purpose of purchasing goods or merchandise, or for collecting
information, for the enterprise;
(e) the maintenance of a fixed place of business
solely for the purpose of advertising, for the supply of information, for
scientific research or for similar activities which have a preparatory or
auxiliary character, for the enterprise.
(4) An enterprise of a Contracting State
shall be deemed to have a permanent establishment in the other Contracting
State if it carries on the activity of providing the services within that
other Contracting State of public entertainers or athletes referred to in 
Article 18.
(5) A person acting in a Contracting State
on behalf of an enterprise of the other Contracting State—other than
an agent of an independent status to whom the provisions of 
paragraph (6) of this Article apply—shall
be deemed to be a permanent establishment in the first-mentioned State if
he has, and habitually exercises in that State, an authority to conclude contracts
in the name of the enterprise, unless his activities are limited to the purchase
of goods or merchandise for the enterprise.
(6) An enterprise of a Contracting State
shall not be deemed to have a permanent establishment in the other Contracting
State merely because it carries on business in that other State through a
broker, general commission agent or any other agent of an independent status,
where such persons are acting in the ordinary course of their business.
(7) The fact that a company which is a resident
of a Contracting State controls or is controlled by a company which is a resident
of the other Contracting State, or which carries on business in that other
State (whether through a permanent establishment or otherwise), shall not
of itself constitute either company a permanent establishment of the other.


ARTICLE 6 
Where under any provision of this Convention income is relieved
from furnish tax and, under the law in force in the United Kingdom, an individual
in respect of the said income is subject to tax by reference to the amount
thereof which is remitted to or received in the United Kingdom and not by
reference to the full amount thereof, then the relief to be allowed under
this Convention in Finland shall apply only to so much of the income as is
remitted to or received in the United Kingdom.

ARTICLE 7 

(1) Income from immovable property may be
taxed in the Contracting State in which such property is situated.
(2) 
(a) The term “immovable
property” shall, subject to the
provisions of sub-paragraph (b)
below, be defined in accordance with the law of the Contracting State in which
the property in question is situated.
(b) The term “immovable
property” shall in any case include
property accessory to immovable property, livestock and equipment used in
agriculture and forestry, rights to which the provisions of general law respecting
landed property apply, usufruct of immovable property and rights to variable
or fixed payments as consideration for the working of, or the right to work,
mineral deposits, sources and other natural resources; ships, boats and aircraft
shall not be regarded as immovable property.
(3) The provisions of 
paragraph (1) of this Article shall apply to
income derived from the direct use, letting, or use in any other form of immovable
property. They shall also apply to income derived as consideration for the
occupation of or the right to occupy immovable property.
(4) The provisions of 
paragraphs (1) and (3)
of this Article shall also apply to the income from immovable property of
an enterprise and to income from immovable property used for the performance
of professional services.

ARTICLE 8 

(1) The profits of an enterprise of a Contracting
State shall be taxable only in that State unless the enterprise carries on
business in the other Contracting State through a permanent establishment
situated therein. If the enterprise carries on business as aforesaid, the
profits of the enterprise may be taxed in the other State but only so much
of them as is attributable to that permanent establishment.
(2) Where an enterprise of a Contracting
State carries on business in the other Contracting State through a permanent
establishment situated therein, there shall in each Contracting State be attributed
to that permanent establishment the profits which it might be expected to
make if it were a distinct and separate enterprise engaged in the same or
similar activities under the same or similar conditions and dealing at arm's
length with the enterprise of which it is a permanent establishment.
(3) In the determination of the profits of
a permanent establishment, there shall be allowed as deductions expenses of
the enterprise (other than expenses which would not be deductible if the permanent
establishment were a separate enterprise) which are incurred for the purposes
of the permanent establishment, including executive and general administration
expenses so incurred, whether in the State in which the permanent establishment
is situated or elsewhere.
(4) In so far as it has been customary in
a Contracting State, according to its law, to determine the profits to be
attributed to a permanent establishment on the basis of an apportionment of
the total income of the enterprise to its various parts, nothing in 
paragraph (2) of this Article shall preclude
that Contracting State from determining the profits to be taxed by such an
apportionment as may be customary; the method of apportionment adopted shall,
however, be such that the result shall be in accordance with the principles
of this Article.
(5) No profits shall be attributed to a permanent
establishment by reason of the mere purchase by that permanent establishment
of goods or merchandise for the enterprise.
(6) For the purposes of the preceding paragraphs,
the profits to be attributed to the permanent establishment shall be determined
by the same method year by year unless there is good and sufficient reason
to the contrary.
(7) Where profits include items which are
dealt with separately in other Articles of this Convention, then the provisions
of those Articles shall not be affected by the provisions of this Article.


ARTICLE 9 
A resident of a Contracting State shall be taxable only
in that Contracting State on profits from the operation of ships or aircraft
other than profits from voyages of ships or aircraft confined solely to places
in the other Contracting State.

ARTICLE 10 
Where
(a) an enterprise of a Contracting State
participates directly or indirectly in the management, control or capital
of an enterprise of the other Contracting State; or
(b) the same persons participate directly
or indirectly in the management, control or capital of an enterprise of a
Contracting State and an enterprise of the other Contracting State;
and in either case conditions are made or imposed between
the two enterprises in their commercial or financial relations which differ
from those which would be made between independent enterprises, then any profits
which would, but for those conditions, have accrued to one of the enterprises,
but, by reason of those conditions, have not so accrued, may be included in
the profits of that enterprise and taxed accordingly.

ARTICLE 11 

(1) Dividends paid by a company being a resident
of a Contracting State which are beneficially owned by a resident of the other
Contracting State may be taxed in that other State.
(2) However, such dividends may also be taxed
in the Contracting State of which the company paying the dividends is a resident,
and according to the law of that State, but the tax so charged shall not exceed:

(a) 5 per cent of the gross amount of the
dividends if the beneficial owner is a company (excluding a partnership) which
controls directly or indirectly at least 25 per cent of the voting power of
the company paying the dividends;
(b) in all other cases, 15 per cent of the
gross amount of the dividends.This paragraph shall not affect the taxation of the company in
respect of the profits out of which the dividends are paid.
(3) The term “dividends”
 as used in this Article means income
from shares or other rights, not being debt-claims, participating in profits,
as well as income from other corporate rights assimilated to income from shares
by the taxation law of the State of which the company making the distribution
is a resident and also includes any other item (other than interest or royalties
relieved from tax under the provisions of Article
12 or Article 13
of this Convention) which, under the law of the Contracting State of which
the company paying the dividend is a resident, is treated as a dividend or
distribution of a company.
(4) The provisions of 
paragraphs (1) and (2)
of this Article shall not apply if the beneficial owner of the dividends,
being a resident of a Contracting State, has in the other Contracting State,
of which the Company paying the dividends is a resident, a permanent establishment
and the holding by virtue of which the dividends are paid is effectively connected
with a business carried on through that permanent establishment. In such a
case, the provisions of Article 8
shall apply.
(5) If the beneficial owner of a dividend
being a resident of a Contracting State owns 10 per cent or more of the class
of shares in respect of which the dividend is paid then the relief from tax
provided for in paragraph (2)
of this Article shall not apply to the dividend to the extent that it can
have been paid only out of profits which the company paying the dividend earned
or other income which it received in a period ending twelve months or more
before the relevant date. For the purposes of this paragraph the term “relevant date” means 
the date on which the beneficial owner of the dividend became the owner of
10 per cent or more of the class of shares in question.Provided that this paragraph shall not apply if the beneficial
owner of the dividend shows that the shares were acquired for bona fide commercial
reasons and not primarily for the purpose of securing the benefit of this
Article.
(6) Where a company which is a resident of
a Contracting State derives profits or income from the other Contracting State,
that other State may not impose any tax on the dividends paid by the company
and beneficially owned by persons who are not residents of that other State,
or subject the company's undistributed profits to a tax on undistributed profits,
even if the dividends paid or the undistributed profits consist wholly or
partly of profits or income arising in that other State.

ARTICLE 12 

(1) Interest derived and beneficially owned
by a resident of a Contracting State shall be taxable only in that State.

(2) The term “interest”
 as used in this Article means income
from Government securities, bonds or debentures, whether or not secured by
mortgage and whether or not carrying a right to participate in profits, and
other debt-claims of every kind as well as all other income assimilated to
income from money lent by the taxation law of the State in which the income
arises.
(3) The provisions of 
paragraph (1) of this Article shall not apply
if the beneficial owner of the interest, being a resident of a Contracting
State, has in the other Contracting State a permanent establishment and the
debt-claim from which the interest arises is effectively connected with a
business carried on through that permanent establishment. In such a case,
the provisions of Article 8
shall apply.
(4) Without prejudice to the provisions of 
paragraph (6) of this Article, any provision
of the law of one of the Contracting States which, with or without any further
requirement, relates only to interest paid to a non-resident company, or which
relates only to interest payments between inter-connected companies with or
without any further requirement, shall not operate so as to require such interest
paid to a company which is a resident of the other Contracting State to be
left out of account as a deduction in computing the taxable profits of the
company paying the interest.
(5) The exemption from tax provided for in 
paragraph (1) of this Article shall not apply
to interest on any form of debt-claim dealt in on a stock exchange where the
beneficial owner of the interest:
(a) does not bear tax in respect thereof
in the Contracting State of which it is a resident; and
(b) sells (or makes a contract to sell) the
debt-claim from which such interest is derived within three months of the
date on which such beneficial owner acquired such debt-claim.
(6) Where, owing to a special relationship
between the payer and the beneficial owner or between both of them and some
other person, the amount of the interest paid, having regard to the debt-claim
for which it is paid, exceeds the amount which would have been agreed upon
by the payer and the beneficial owner in the absence of such relationship,
the provisions of this Article shall apply only to the last-mentioned amount.
In that case, the excess part of the payments shall remain taxable according
to the law of each Contracting State, due regard being had to the other provisions
of this Convention.
(7) The provisions of this Article shall
not apply if the debt-claim in respect of which the interest is paid was created
or assigned mainly for the purpose of taking advantage of this Article and
not for bona fide commercial reasons.

ARTICLE 13 

(1) Royalties derived and beneficially owned
by a resident of a Contracting State shall be taxable only in that State.

(2) The term “royalties”
 as used in this Article means payments
of any kind received as a consideration for the use of, or the right to use,
any copyright of literary, artistic or scientific work (including cinematograph
films, and films or tapes for radio or television broadcasting), any patent,
trade mark, design or model, plan, secret formula or process, or for the use
of, or the right to use, industrial, commercial or scientific equipment, or
for information concerning industrial, commercial or scientific experience
.
(3) The provisions of 
paragraph (1) of this Article shall not apply
if the beneficial owner of the royalties, being a resident of a Contracting
State, has in the other Contracting State a permanent establishment and the
right or property giving rise to the royalties is effectively connected with
a business carried on through that permanent establishment. In such a case,
the provisions of Article 8
shall apply.
(4) Without prejudice to the provisions of 
paragraph (5) of this Article, any provision
of the law of a Contracting State which requires royalties paid by a company
to be left out of account as a deduction in computing the company's taxable
profits as being a distribution shall not operate in relation to royalties
paid to a resident of the other Contracting State. The preceding sentence
shall not however apply to royalties derived and beneficially owned by a company
which is a resident of that other Contracting State where:
(a) the same persons participate directly
or indirectly in the management or control of the company paying the royalties
and the company beneficially owning the royalties; and
(b) more than 50 per cent of the voting power
in the company beneficially owning the royalties is controlled directly or
indirectly by a person or persons resident in the Contracting State in which
the company paying the royalties is resident.
(5) Where, owing to a special relationship
between the payer and the beneficial owner or between both of them and some
other person, the amount of the royalties paid, having regard to the use,
right or information for which they are paid, exceeds the amount which would
have been agreed upon by the payer and the beneficial owner in the absence
of such relationship, the provisions of this Article shall apply only to the
last-mentioned amount. In that case, the excess part of the payments shall
remain taxable according to the law of each Contracting State, due regard
being had to the other provisions of this Convention.

ARTICLE 14 

(1) Capital gains from the alienation of
immovable property, as defined in paragraph (2)
of Article 7, may be taxed in the Contracting
State in which such property is situated.
(2) Capital gains from the alienation of
movable property forming part of the business property of a permanent establishment
which an enterprise of a Contracting State has in the other Contracting State
or of movable property pertaining to a fixed base available to a resident
of a Contracting State in the other Contracting State for the purpose of performing
professional services, including such gains from the alienation of such a
permanent establishment (alone or together with the whole enterprise) or of
such a fixed base, may be taxed in the other State.
(3) Notwithstanding the provisions of 
paragraph (2) of this Article, capital gains
derived by a resident of a Contracting State from the alienation of ships
and aircraft operated in international traffic and movable property pertaining
to the operation of such ships and aircraft shall be taxable only in that
Contracting State.
(4) Capital gains from the alienation of
any property other than those mentioned in paragraphs
(1), (2) and 
(3) of this Article shall be taxable only in
the Contracting State of which the alienator is a resident.
(5) The provisions of 
paragraph (4) of this Article shall not affect
the right of a Contracting State to levy according to its own law a tax on
capital gains from the alienation of any property derived by an individual
who is a resident of the other Contracting State and has been a resident of
the first-mentioned Contracting State at any time during the five years immediately
preceding the alienation of the property.

ARTICLE 15 

(1) Income derived by a resident of a Contracting
State in respect of professional services or other independent activities
of a similar character shall be taxable only in that State unless he has a
fixed base regularly available to him in the other Contracting State for the
purpose of performing his activities. If he has such a fixed base, the income
may be taxed in the other Contracting State but only so much of it as is attributable
to that fixed base.
(2) The term “professional
services” includes especially independent
scientific, literary, artistic, educational or teaching activities as well
as the independent activities of physicians, lawyers, engineers, architects,
dentists and accountants.

ARTICLE 16 

(1) Subject to the provisions of 
Articles 17, 19, 
20, 21 and 
22, salaries, wages and other similar remuneration
derived by a resident of a Contracting State in respect of an employment shall
be taxable only in that State unless the employment is exercised in the other
Contracting State. If the employment is so exercised, such remuneration as
is derived therefrom may be taxed in that other State.
(2) Notwithstanding the provisions of 
paragraph (1) of this Article, remuneration
derived by a resident of a Contracting State in respect of an employment exercised
in the other Contracting State shall be taxable only in the first-mentioned
State if:
(a) the recipient is present in the other
State for a period or periods not exceeding in the aggregate 183 days in the
fiscal year concerned; and
(b) the remuneration is paid by, or on behalf
of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent
establishment or a fixed base which the employer has in the other State.
(3) Notwithstanding the preceding provisions
of this Article, remuneration in respect of an employment exercised aboard
a ship or aircraft in international traffic may be taxed in the Contracting
State of which the person deriving the profits from the operation of the ship
or aircraft is a resident.

ARTICLE 17 

Directors' fees and similar payments derived by a resident of a Contracting
State in his capacity as a member of the board of directors of a company which
is a resident of the other Contracting State may be taxed in that other State.


ARTICLE 18 
Notwithstanding the provisions of 
Articles 15 and 16,
income derived by public entertainers, such as theatre, motion picture, radio
or television artistes, and musicians, and by athletes, from their personal
activities as such may be taxed in the Contracting State in which those activities
are exercised.

ARTICLE 19 

(1) Subject to the provisions of 
paragraphs (1) and (2) of Article 20
, pensions and other similar remuneration paid
in consideration of past employment to a resident of a Contracting State and
any annuity paid to such a resident shall be taxable only in that State.
(2) The term “annuity”
 means a stated sum payable periodically
at stated times during life or during a specified or ascertainable period
of time under an obligation to make the payments in return for adequate and
full consideration in money or money's worth.

ARTICLE 20 

(1) Remuneration or pensions paid out of
public funds of the United Kingdom or Northern Ireland or of the funds of
any local authority in the United Kingdom to any individual in respect of
services rendered to the Government of the United Kingdom or Northern Ireland
or a local authority in the United Kingdom in the discharge of functions of
a governmental nature, shall be taxable only in the United Kingdom unless
the individual is a Finnish national without also being a United Kingdom national.

(2) Remuneration or pensions paid by, or
out of funds created by Finland or a local authority or public community thereof
to any individual in respect of services rendered to the Government of Finland
or a local authority or public community thereof, in the discharge of functions
of a governmental nature, shall be taxable only in Finland unless the individual
is a national of the United Kingdom without also being a Finnish national.

(3) The provisions of 
paragraphs (1) and (2)
of this Article shall not apply to remuneration or pensions in respect of
services rendered in connection with any trade or business.

ARTICLE 21 

(1) An individual who is a resident of a
Contracting State immediately before his visit to the other Contracting State
and who is temporarily present in that other Contracting State solely:
(a) as a student at a university, college,
school or other educational institution; or
(b) as a business, technical, agricultural
or forestry apprentice; or
(c) as the recipient of a grant, allowance
or award from a religious, charitable, scientific or educational organisation
made for the primary purpose of study;shall not be taxed in that other Contracting State in respect of:

(i) remittances from abroad for the purpose
of his maintenance, education or training;
(ii) the grant, allowance or award; and
(iii) remuneration for services rendered
in that other Contracting State, provided that the services are in connection
with his studies or training or the remuneration constitutes earnings reasonably
necessary for his maintenance or education.
(2) The benefits under the provisions of 
paragraph (1) of this Article shall extend
only for such period of time as may be reasonably or customarily required
to effectuate the purpose of the visit, but in no event shall any individual
have the benefits of the provisions of that paragraph for more than five years.

(3) An individual who is, or was immediately
before visiting a Contracting State, a resident of the other Contracting State,
and who is present in the first-mentioned Contracting State as a recipient
of a grant, allowance or award from a religious, charitable, scientific or
educational organisation made for the primary purpose of research to be carried
out in a period which does not exceed two years, shall not be taxed in that
first-mentioned Contracting State in respect of the grant, allowance or award.


ARTICLE 22 

A professor or teacher who visits a Contracting State for a period not exceeding
two years for the purpose of teaching at a university, college, school or
other educational institution in that Contracting State and who is, or was
immediately before that visit, a resident of the other Contracting State shall
be exempt from tax in the first-mentioned Contracting State on any remuneration
for such teaching in respect of which he is subject to tax in the other Contracting
State.

ARTICLE 23 
Items of income of a resident of a Contracting State being
income of a class or from sources not expressly mentioned in the foregoing
Articles of this Convention shall be taxable only in that State.

ARTICLE 24 

(1) Capital represented by immovable property,
as defined in paragraph (2) of Article 7,
may be taxed in the Contracting State in which such property is situated.

(2) Capital represented by movable property
forming part of the business property of a permanent establishment of an enterprise,
or by movable property pertaining to a fixed base used for the performance
of professional services, may be taxed in the Contracting State in which the
permanent establishment or fixed base is situated.
(3) Notwithstanding the provisions of 
paragraph (2) of this Article, ships and aircraft
operated in international traffic and movable property pertaining to the operation
of such ships and aircraft shall be taxable only in the Contracting State
of which the operator is a resident.
(4) All other elements of capital of a resident
of a Contracting State shall be taxable only in that State.

ARTICLE 25 

(1) Subject to the provisions of the law
of the United Kingdom regarding the allowance as a credit against United Kingdom
tax of tax payable in a territory outside the United Kingdom (which shall
not affect the general principle hereof):
(a) Finnish tax payable under the laws of
Finland and in accordance with this Convention, whether directly or by deduction,
on profits, income or chargeable gains from sources within Finland (excluding
in the case of a dividend, tax payable in respect of the profits out of which
the dividend is paid) shall be allowed as a credit against any United Kingdom
tax computed by reference to the same profits, income or chargeable gains
by reference to which the Finnish tax is computed;
(b) in the case of a dividend paid by a company
which is a resident of Finland to a company which is a resident of the United
Kingdom and which controls directly or indirectly at least 10 per cent of
the voting power in the company paying the dividend, the credit shall take
into account (in addition to any Finnish tax creditable under the provisions
of sub-paragraph (a)
of this paragraph) the Finnish tax payable by the company in respect of the
profits out of which such dividend is paid, if at the time when the dividend
is paid a company which is a resident of Finland is exempt from Finnish tax
in respect of dividends received from a company which is a resident of Finland.

(2) 
(a) Where a resident of Finland derives income
or owns capital which, in accordance with the provisions of this Convention,
may be taxed in the United Kingdom, Finland shall, subject to the provisions
of sub-paragraph (b)
of this paragraph, allow as a deduction from the income or capital tax that
part of the income tax or capital tax, respectively, which is appropriate,
as the case may be, to the income derived from or the capital owned in the
United Kingdom.
(b) Where a resident of Finland derives income
or chargeable gains which, in accordance with the provisions of 
paragraph (2) of Article 11 and paragraph
(5) of Article 14 may be taxed in the United
Kingdom, Finland shall allow as a deduction from the tax on the income of
that person an amount equal to the tax paid in the United Kingdom. Such deduction
shall not, however, exceed that part of the tax, as computed before the deduction
is given, which is appropriate to the income or chargeable gains derived from
the United Kingdom.
(c) Notwithstanding the provisions of 
sub-paragraph (b) of this paragraph, dividends
paid by a company which is a resident of the United Kingdom to a company which
is a resident of Finland shall be exempt from Finnish tax. This exemption
shall not apply unless in accordance with the laws of Finland the dividends
would have been exempt from Finnish tax if the first-mentioned company had
been a resident of Finland and not a resident of the United Kingdom.
(d) Where a resident of Finland derives income
which in accordance with the provisions of paragraph
(1) of Article 20 shall be taxable only in
the United Kingdom, such income shall be exempt from Finnish tax; however,
the graduated rates of Finnish tax may be calculated as though income thus
exempted were included in the amount of the total income.
(3) For the purposes of 
paragraph (1) of this Article income, profits
and capital gains owned by a resident of the United Kingdom which may be taxed
in Finland in accordance with this Convention shall be deemed to arise from
sources in Finland.

ARTICLE 26 

(1) Subject to the provisions of 
paragraph (3) of this Article, individuals
who are residents of Finland shall be entitled to the same personal allowances,
reliefs and reductions for the purposes of United Kingdom tax as British subjects
not resident in the United Kingdom.
(2) Subject to the provisions of 
paragraph (3) of this Article, individuals
who are residents of the United Kingdom shall be entitled to the same personal
allowances, reliefs and reductions for the purposes of Finnish tax as Finnish
nationals not resident in Finland.
(3) Nothing in this Convention shall entitle
an individual who is a resident of a Contracting State and whose income from
the other Contracting State consists solely of dividends, interest or royalties
(or solely of any combination thereof) to the personal allowances, reliefs
and reductions of the kind referred to in this Article for the purposes of
taxation in that other Contracting State.

ARTICLE 27 

(1) The nationals of a Contracting State
shall not be subjected in the other Contracting State to any taxation or any
requirement connected therewith which is other or more burdensome than the
taxation and connected requirements to which nationals of that other State
in the same circumstances are or may be subjected.
(2) The taxation on a permanent establishment
which an enterprise of a Contracting State has in the other Contracting State
shall not be less favourably levied in that other State than the taxation
levied on enterprises of that other State carrying on the same activities.

(3) Enterprises of a Contracting State, the
capital of which is wholly or partly owned or controlled, directly or indirectly
by one or more residents of the other Contracting State, shall not be subjected
in the first-mentioned Contracting State to any taxation or any requirement
connected therewith which is other or more burdensome than the taxation and
connected requirements to which other similar enterprises of that first-mentioned
State are or may be subjected.
(4) In determining for the purpose of United
Kingdom tax whether a company is a close company, the term 
“recognised stock exchange” 
shall include the Helsinki Stock Exchange.
(5) Nothing contained in this Article shall
be construed as obliging either Contracting State to grant to individuals
not resident in that State any of the personal allowances, reliefs and reductions
for tax purposes which are granted to individuals so resident, nor as obliging
the United Kingdom to grant to a company which is a resident of Finland a
greater relief from United Kingdom income tax chargeable upon dividends received
from a company which is a resident of the United Kingdom than the relief to
which the first-mentioned company may be entitled under the provisions of 
Article 11 of this Convention.
(6) In this Article the term “taxation” means 
taxes of every kind and description.

ARTICLE 28 

(1) Where a resident of a Contracting State
considers that the actions of one or both of the Contracting States result
or will result for him in taxation not in accordance with this Convention,
he may, notwithstanding the remedies provided by the national laws of those
States, present his case to the competent authority of the Contracting State
of which he is a resident.
(2) The competent authority shall endeavour,
if the objection appears to it to be justified and if it is not itself able
to arrive at an appropriate solution, to resolve the case by mutual agreement
with the competent authority of the other Contracting State, with a view to
the avoidance of taxation not in accordance with the Convention.
(3) The competent authorities of the Contracting
States shall endeavour to resolve by mutual agreement any difficulties or
doubts arising as to the interpretation or application of the Convention.

(4) The competent authorities of the Contracting
States may communicate with each other directly for the purpose of reaching
an agreement in the sense of the preceding paragraphs.

ARTICLE 29 
The competent authorities of the Contracting States shall exchange
such information (being information which is at their disposal under their
respective taxation laws in the normal course of administration) as is necessary
for carrying out the provisions of this Convention or for the prevention of
fraud or the administration of statutory provisions against legal avoidance
in relation to the taxes which are the subject of this Convention. Any information
so exchanged shall be treated as secret but may be disclosed to persons (including
a court or administrative body) concerned with assessment, collection, enforcement
or prosecution in respect of taxes which are the subject of this Convention.
No information shall be exchanged which would disclose any trade, business,
industrial or professional secret or any trade process.

ARTICLE 30 

(1) This Convention may be extended, either
in its entirety or with modifications, to any territory for whose international
relations either Contracting Party is responsible and which imposes taxes
substantially similar in character to those to which this Convention applies.
Any such extension shall take effect from such date and subject to such modifications
and conditions, including conditions as to termination, as may be specified
and agreed between the Contracting States in notes to be exchanged through
diplomatic channels.
(2) Unless otherwise agreed by both Contracting
States, the termination of this Convention shall terminate the application
of this Convention to any territory to which it has been extended under the
provisions of this Article.

ARTICLE 31 

(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 6th
April, 1968; and
(ii) as respects corporation tax, for any
financial year beginning on or after 1st April, 1968;
(b) in Finland:as respects Finnish taxes for any year of assessment beginning
on or after 1st 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 12th December, 1951, as amended
by the Protocol signed at London on 16th 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.

(6) The following Agreements between the
Contracting Parties shall not have effect in relation to any tax for any period
for which this Convention has effect, as respects that tax:
(a) the Agreement between the Government
of the United Kingdom and the Government of Finland for the Reciprocal Exemption
from Income Tax in certain cases of Profits from the Business of Shipping
signed at London on 18th November, 1925;
(b) the Agreement between the Government
of the United Kingdom and the Government of Finland for the Reciprocal Exemption
from Income Tax in certain cases of Profits or Gains arising through an Agency
signed at London on 21st February, 1935.
(7) The 1951
Convention shall terminate on the last date
on which it has effect in accordance with the foregoing provisions of this
Article.

ARTICLE 32 

This Convention shall remain in force until denounced by one of the Contracting
States. Either Contracting State may denounce the Convention, through diplomatic
channels, by giving notice of termination at least six months before the end
of any calendar year after the year 1972. In such event, the Convention shall
cease to 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 6th
April in the calendar year next following that in which the notice is given;

(ii) as respects corporation tax, for any
financial year beginning on or after 1st April in the calendar year next following
that in which the notice is given;
(b) in Finland:as respects Finnish tax for any tax year beginning on or after
1st January in the calendar year next following that in which the notice is
given.
In witness whereof the undersigned, duly authorised thereto
by their respective Governments, have signed this Convention.
Done in duplicate at London this 17th day of July, 1969, in the
English and Finnish languages, both texts being equally authoritative.
