- Date of issue
- In force until further notice
Full texts of the tax treaties are also available at Valtion säädöstietopankki (Finlex). Use the reference numbers listed below.
Click the links below to access electronic versions of tax treaties. Not all of them are available in this format. Treaty texts have an introductory passage in Finnish after which the English version begins, if included.
Some treaties have been amended. In this case, the list mentions the amendments on the next line after the country name. When treaty provisions are applied, amendments must be considered. Examples of what amendments may concern: the taxing rights of Contracting States, the applicable rates of withholding at source.
The impact of the Multilateral Instrument on how tax treaties are applied
On 13 February 2019, the Finnish Parliament ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument”) made in 2016. The Multilateral Instrument provides for simultaneous modification of a number of provisions in bilateral tax treaties without making changes to every treaty one by one. The decree (in Finnish and Swedish, link to Finnish) of 24 April 2019 of the Finnish government contains information on how Finland ratified the Multilateral Instrument with appropriate reservations and notifications, in Finland’s letter of ratification, sent to the Depositary, and it also contains the text of the Multilateral Instrument.
The date when the Multilateral Instrument comes into force in Finland was 1 June 2019. However, any two contracting states of bilateral tax treaties will not start applying the Multilateral Instrument until such time as the Instrument has come into force in both of them. The Finnish official publication called “Collection of Statutes” (Säädöskokoelma; Författningssamling) contains specific notices, recorded by the Ministry of Finance, for each country that has a tax treaty with Finland and where the Multilateral Instrument has come into force. These notices are listed under every tax treaty in force, and under treaty amendments, if any.
The Multilateral Instrument makes those provisions of the Convention necessary to meet the minimum standard included in the Instrument become part of Finland’s network of tax treaties with other countries. These provisions are the introductory chapter of tax treaties, which addresses the purpose of the treaty, the provision on preventing treaty abuse, the revised provisions on the mutual agreement procedure, and the provision on corresponding adjustments related to transfer pricing of group enterprises. In addition, Finland will apply the Multilateral Instrument’s provisions on arbitration. Regarding the other provisions, Finland made reservations, i.e. refrains from applying those provisions of the Multilateral Instrument. If Finland or the other party to the Multilateral Instrument has made a reservation, having the effect of not applying the Multilateral Instrument’s provisions on the tax treaties of the country concerned, there will be no modification to the relevant provisions in the existing bilateral tax treaty. This means that Finland, on its part, will not apply the provision of the Multilateral Instrument. Instead, it applies the provision of the existing bilateral tax treaty.
When applying the provisions of tax treaties, one must take account of the original tax treaty, its protocols of amendments, of the Multilateral Instrument, and of any reservations and notifications that the contracting states have made. In the future, the Finlex website will post all the currently valid versions of Finland’s tax treaties with other countries. In addition, for the treaties that the Multilateral Instrument modifies when applied, the website will post all the relevant provisions having an impact on the tax treaty concerned. This will be presented in a compilation document. A line will be added below the heading of every tax treaty, containing information on updates and relevant compilation documents. Such lines are added one by one at various times when the documents are ready for publication. The purpose of having current updates and compilations posted on the Web is to make it easier to understand the entirety of those of the treaties that consist of many parts. However, only the treaties themselves are authentic for purposes of law.
|OECD member countries:||Other countries:|
Czech Republic 80/1995
South Korea 75/1981
Armenia 120/2007 (pdf)
Aruba 65/2011 (pdf) 2)
Azerbaijan 94/2006 (pdf)
Belarus 84/2008 (pdf)
Bermuda 87/2009 (pdf) 2)
British Virgin Islands 59/2011 (pdf) 2)
Cayman Islands 34/2010 (pdf) 2)
Hong Kong 79/2018 (pdf)
Isle of Man 74/2008 (pdf) 2)
Jersey 78/2009 (pdf) 2)
Kazakhstan 85/2010 (pdf)
Kosovo (see Yugoslavia)
Macedonia 23/2002 (pdf)
Moldova 92/2008 (pdf)
Montenegro (see Yugoslavia)
Netherlands Antilles 63/2011 (pdf) 2)
Romania 7/2000 (pdf)
Serbia (see Yugoslavia)
South Africa 78/1995
Tajikistan 72/2013 (pdf)
1) The tax treaty between Finland and former Yugoslavia (SopS 60/1987) is applicable to international tax situations where Croatia, Bosnia-Hertsegovina, Montenegro, Kosovo or Serbia is involved with Finland being the opposite party. For more information, see the official statements of the Finnish Ministry for Foreign Affairs 17.5.1995, SopS 70/2001, SopS 75/2005, SopS 9/2016 and the official statements 18.4.2007, 31.1.2012 and 2.2.016.
2) An agreement on tax information + a limited-scope tax treaty.
South Africa ZA
Sri Lanka LK
Denmark (Faroe Is.) DK
United Kingdom GB
United States US
United Arab Emirates AE
New Zealand NZ
Russian Federation RU
*There is no country code for Kosovo in the international standards (ISO). To denote Kosovo, XK is occasionally used until an ISO code is confirmed.