The Double Taxation Relief (Taxes on Income) (Finland) Order 1991

ARTICLE VIII

Paragraph (2) of Article 25 of the Convention shall be deleted and replaced by the following:

“(2) In Finland double taxation shall be eliminated as follows:

(a) Where a resident of Finland derives income or chargeable gains which, in accordance with the provisions of the 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 tax on income of that person, an amount equal to the tax on income or chargeable gains paid in the United Kingdom. Such deduction shall not, however, exceed that part of the tax on income, as computed before the deduction is given, which is attributable to the income or chargeable gains which may be taxed in the United Kingdom.

(b) Where a company which is a resident of Finland receives a tax credit under sub-paragraph (c) of paragraph (5) of Article 11 in respect of a dividend paid by a company which is a resident of the United Kingdom, the first-mentioned company shall be exempt from Finnish tax on the amount of the dividend. In that case, Finland shall allow as a deduction from the tax on the income of that company an amount equal to such proportion of the tax paid in the United Kingdom as the tax credit bears to the aggregate of the dividend and the tax credit. Such deduction shall not exceed that part of the Finnish tax as computed before the deduction is given, as is appropriate to the United Kingdom tax credit.

(c) Where a resident of Finland derives income which, in accordance with the provisions 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.”