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Tax treaties

The Ministry of Finance is responsible for preparing tax treaties that are binding on Finland. These include income tax treaties, inheritance and gift tax treaties, tax information exchange agreements (TIEAs) and agreements on executive assistance. The business community or an individual company may be the source, directly or indirectly, of an initiative to start negotiations on a treaty or agreement.

With income tax treaties and inheritance and gift tax treaties the right to tax income and inheritance is divided between the contracting states. The primary purpose of such treaties is to eliminate double taxation, while the secondary purpose is to try to reduce the complexity of taxation. Although national legislation determines the extent of Finland's ability to levy taxes, the taxing right based on national legislation may be restricted by tax treaties.

In tax information exchange agreements the contracting states agree on exchange of information on tax matters between their authorities in order to receive information that is needed for national taxation. In the agreements on executive assistance, agreement is also made on recovery of taxes, notification of tax documents, simultaneous tax audits and participation in tax audits in the other contracting state.

Finland’s current tax treaties are published on the Finlex website:

Finlex

Signed tax treaties

Treaties are published in the Treaty Series of the Statute Book of Finland at the time of their entry into force. An online version of the Treaty Series is published on the Finlex website. Below are the texts of treaties that have been signed but have not yet entered into force.

Germany: A Protocol between Finland and Germany to amend their bilateral income tax treaty was signed 18 November 2019.

Protocol between Finland and Germany

Portugal: A new tax treaty between Finland and Portugal was signed on 7 November 2016. The Finnish Parliament has approved the treaty, but in Portugal the treaty has not yet been submitted to the country’s parliament, and so is not yet in force.

Treaty between Finland and Portugal

Memorandums

Information on agreements of general significance made under any of the treaties by the competent authorities is normally published in the Treaty Series of the Statute Book of Finland. This page brings together memorandums of understanding concluded by the Ministry of Finance in its capacity as competent authority but not published in the Treaty Series, and information on mutual agreements made by the Ministry of Finance as competent authority.

Thailand: The competent authorities of Finland and Thailand have, through an exchange of letters, concluded a mutual agreement stating that Article 11, paragraph 4 of the treaty also refers to Finnish Export Credit plc and Export–Import Bank of Thailand. This will apply from 1 January 2001.

Russia:

Memorandum of understanding 13 April 2000

Memorandum of understanding 9 November 2004