Frequently asked questions (FAQs)

Q: What does the database contain?

A: The database contains income tax treaties concluded by Finland that correspond in scope to the OECD Model Tax Convention. The treaties are in Finnish and Swedish. Also English language version has been included if the treaty has been concluded in English language. The treaties consist of currently valid treaty texts, many of which are synthesised texts. Income tax treaties are treaties on the avoidance of double taxation. The database does not contain any other tax treaties, such as treaties on gift and inheritance tax or on the exchange of information.

Q: What are 'currently valid’ texts?

A: ‘Currently valid’ means that the text incorporates any amendments made to the original treaty under amending protocols. The currently valid treaty texts therefore incorporate any such protocol changes made to the original texts. Many of the treaty texts are presented as synthesised texts (see Q&A on synthesised texts). If there have been no amendments to a tax treaty, then the original text will still be currently valid unless it has been subject to any modifications as a synthesised version.

Q: What are ‘synthesised’ texts?

A: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (‘the Convention’), which is in force in Finland, does not amend a tax treaty in the same way as a protocol, but instead is applied alongside the tax treaty. The resulting synthesised text is then one in which the Convention’s provisions appear alongside the tax treaty in a single document. The provisions of the Convention are shown in text boxes.

Q: Why are some treaties shown as synthesised texts and some not?

A: This is because the Convention is not applicable alongside every tax treaty, for various reasons. For instance, not all of Finland’s tax treaty partners are parties to the Convention. So the synthesised texts in the database are only for those treaties to which the Convention is applicable. For other treaties, the currently valid text is the original treaty as amended through any amending protocols.

Q: What are protocols?

A: At the end of some tax treaties, a protocol is shown by the signature, and the provisions of such a protocol are an essential part of the treaty. The protocol provisions may relate to the entire treaty or to a specific article, but the protocol itself is given at the end of the treaty.

Tax treaties are amended by means of an amending protocol to the treaty, and in the database such amendments are made to the original tax treaties using the same principles followed when legislation is updated.

Q: Can the database versions (i.e. currently valid texts, many of which are synthesised texts) be considered authentic documents?

A: No, they cannot. The authentic versions are the treaties, the protocols and the Convention published in the Treaty Series of the Statute Book of Finland. Each treaty indicates which are the authentic language versions.

Q: Some texts are not shown – when will these be added?

A: The aim is to add the missing texts before the end of 2020.

Q: The database does not show a synthesised or otherwise currently valid version of the treaty I am looking for. Where can these texts be viewed?

A: Treaties, protocols and the Convention are published in the Treaty Series of the Statute Book of Finland.

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