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        <preface>
            <p>
                <docNumber>1-2/2007</docNumber>
                <docTitle>Convention between Finland and Canada for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income</docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN FINLAND AND CANADA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME</heading>
                        <p>This document presents the synthesised text for the application of the Convention
      between Finland and Canada for the avoidance of double taxation and the prevention of fiscal
      evasion with respect to taxes on income signed on 20 July 2006 (the “Convention”), as modified
      by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base
      Erosion and Profit Shifting signed by the Republic of Finland and Canada on 7 June 2017 (the
      “MLI”).</p>
                        <p>This document was prepared by the Competent Authority of Finland and represents its
      understanding of the modifications made to the Convention by the MLI. In preparing this
      document, the Competent Authority of Finland consulted with Canadian officials.</p>
                        <p>The document was prepared on the basis of the MLI position of the Republic of Finland
      submitted to the Depositary upon acceptance on 25 February 2019 and of the MLI position of
      Canada submitted to the Depositary upon ratification on 29 August 2019. These MLI positions
      are subject to modifications as provided in the MLI. Modifications made to MLI positions could
      modify the effects of the MLI on the Convention. The document also contains the modifications
      resulting from the withdrawal of the reservation made by the Republic of Finland to Article 9
      of the MLI (consolidated MLI position of the Republic of Finland on 27 June 2023).</p>
                        <p>The authentic legal texts of the Convention and the MLI take precedence and remain the
      legal texts applicable. </p>
                        <p>The provisions of the MLI that are applicable with respect to the provisions of the
      Convention are included in boxes throughout the text of this document in the context of the
      relevant provisions of the Convention. The boxes containing the provisions of the MLI have
      generally been inserted in accordance with the ordering of the provisions of the 2017 OECD
      Model Tax Convention.</p>
                        <p>Changes to the text of the provisions of the MLI have been made to conform the
      terminology used in the MLI to the terminology used in the Convention (such as “Covered Tax
      Agreement” and “Convention”, “Contracting Jurisdictions” and “Contracting States”), to ease
      the comprehension of the provisions of the MLI. The changes in terminology are intended to
      increase the readability of the document and are not intended to change the substance of the
      provisions of the MLI. Similarly, changes have been made to parts of provisions of the MLI
      that describe existing provisions of the Convention: descriptive language has been replaced by
      legal references of the existing provisions to ease the readability.</p>
                        <p>In all cases, references made to the provisions of the Convention or to the Convention
      must be understood as referring to the Convention as modified by the provisions of the MLI,
      provided such provisions of the MLI have taken effect.</p>
                        <p>
                            <b>Entry into Effect of the MLI Provisions</b>
                        </p>
                        <p>The provisions of the MLI applicable to this Convention do not take effect on the same
      dates as the original provisions of the Convention. Each of provisions of the MLI could take
      effect on different dates, depending on the types of taxes involved (taxes withheld at source
      or other taxes levied) and on the choices made by the Republic of Finland and Canada in their
      MLI positions.</p>
                        <p>Dates of the deposit of instruments of ratification, acceptance or approval: 25
      February 2019 for the Republic of Finland and 29 August 2019 for Canada.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 December
      2019 for Canada.</p>
                        <p>This document provides specific information on the dates on or after which each of the
      provisions of the MLI has effect with respect to the Convention throughout this
      document.</p>
                        <p>
                            <b>References</b>
                        </p>
                        <p>The authentic legal texts of the MLI can be found on the MLI Depositary (OECD)
      webpage:</p>
                        <p>
                            – in English:
                            <a href="http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf">http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf</a>
                                  and
                        </p>
                        <p>
                            – in French:
                            <a href="http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf">http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf</a>
                        </p>
                        <p>
                            The MLI position of the Republic of Finland submitted to the Depositary upon
      acceptance on 25 February 2019, the consolidated MLI position of the Republic of Finland
      submitted to the Depositary on 27 June 2023 and the MLI position of Canada submitted to the
      Depositary upon ratification on 29 August 2019 can be found on the MLI Depositary (OECD)
      webpage:
                            <a href="http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf">http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf</a>
                        </p>
                        <p>
                            The MLI Matching Database is publicly available on the OECD webpage:
                            <a href="http://www.oecd.org/tax/treaties/mli-matching-database.htm">http://www.oecd.org/tax/treaties/mli-matching-database.htm</a>
                        </p>
                        <p>
                            The Act on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent
      Base Erosion and Profit Shifting is published in Statute Book of Finland 231/2019. Link to
      Finnish language version
                            <a href="https://www.finlex.fi/fi/laki/alkup/2019/20190231">https://www.finlex.fi/fi/laki/alkup/2019/20190231</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/laki/alkup/2019/20190231">https://www.finlex.fi/sv/laki/alkup/2019/20190231</a>
                        </p>
                        <p>
                            The Government´s Statute on the entry into force of the MLI and the Act and the
      Finnish text (translation) of the MLI is published in the Treaty Series of the Statute Book of
      Finland SopS 21-22/2019. Links to Finnish language versions
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190021">https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190021</a>
                                  and
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190022">https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190022</a>
                                  Links to Swedish language versions
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190021.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190021.pdf</a>
                                  and
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190022.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190022.pdf</a>
                        </p>
                        <p>
                            The Announcement of the Ministry of Finance on withdrawal of reservation made to
      Article 9 of the MLI and on additional notifications is published in the Treaty Series of the
      Statute Book of Finland SopS 48/2023. Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2023/20230048/20230048_1">https://finlex.fi/fi/sopimukset/sopsteksti/2023/20230048/20230048_1</a>
                                  Link to Swedish language version
                            <a href="https://finlex.fi/sv/sopimukset/sopimussarja/2023/fds20230048.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2023/fds20230048.pdf</a>
                        </p>
                        <p>
                            The Announcement of the Ministry of Finance on the entry into force of the MLI in
      Canada is published in the Treaty Series of the Statute Book of Finland SopS 83/2019. Link to
      Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2019/20190083">https://finlex.fi/fi/sopimukset/sopsteksti/2019/20190083</a>.
      Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/20190083.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2019/20190083.pdf</a>
                        </p>
                        <p>
                            Convention between Finland and Canada for the avoidance of double taxation and the
      prevention of fiscal evasion with respect to taxes on income signed on 20 July 2006 is
      published in the Treaty Series of the Statute Book of Finland SopS 2/2007. Link to Finnish
      language version
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2007/20070002">https://www.finlex.fi/fi/sopimukset/sopsteksti/2007/20070002</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2007/20070001.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2007/20070001.pdf</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Convention between Finland and Canada for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income</p>
            <tblock class="noteEditorial" eId="note_1" finlex:outline="huomautus">
                <p>
                    See changes and notifications to the agreement from
                    <a href="https://www.edilex.fi/valtiosopimukset/20070002">the Finnish version</a>.
                </p>
            </tblock>
            <p>The Government of Finland and the Government of Canada, </p>
            <p>Desiring to conclude a Convention for the avoidance of double taxation and the
    prevention of fiscal evasion with respect to taxes on income, </p>
            <p>
                <embeddedStructure class="mli-addition">
                    <p>
                        <authorialNote>
                            <p>
                                The following paragraph 1 of Article 6 of the MLI is included in the preamble of
      this Convention:
                                <authorialNote marker="1" placement="bottom">
                                    <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
          Article 6 of the MLI has effect with respect to the application of this Convention by the
          Republic of Finland:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2020;
          and</p>
                                    <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2021;</p>
                                    <p>and,</p>
                                    <p>In accordance with paragraph 1 of Article 35 of the MLI, paragraph 1 of Article 6
          of the MLI has effect with respect to the application of the Convention by
          Canada:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2020;
          and</p>
                                    <p>b) with respect to all other taxes levied by Canada, for taxes levied with respect
          to taxable periods beginning on or after 1 June 2020.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 6 OF THE MLI – PURPOSE OF A COVERED TAX AGREEMENT</num>
                        <content>
                            <p>
                                Intending to eliminate double taxation with respect to the taxes covered by
          [
                                <i>this Convention</i>
                                ] without creating opportunities for non-taxation
        or reduced taxation through tax evasion or avoidance (including through treaty-shopping
        arrangements aimed at obtaining reliefs provided in [
                                <i>the Convention</i>
                                ]
        for the indirect benefit of residents of third jurisdictions),
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <p>Have agreed as follows:</p>
        </preamble>
        <mainBody>
            <article eId="art_1">
                <num>Article 1</num>
                <heading>Persons Covered</heading>
                <content>
                    <p>This Convention shall apply to persons who are residents of one or both of the
      Contracting States.</p>
                </content>
            </article>
            <article eId="art_2">
                <num>Article 2</num>
                <heading>Taxes Covered</heading>
                <content>
                    <p>1. The existing taxes to which this Convention shall apply are:</p>
                    <p>a) in the case of Canada: the income taxes imposed by the Government of Canada under
      the Income Tax Act, </p>
                    <p>(hereinafter referred to as "Canadian tax"); and</p>
                    <p>b) in the case of Finland:</p>
                    <p>(i) the state income taxes;</p>
                    <p>(ii) the corporate income tax;</p>
                    <p>(iii) the communal tax;</p>
                    <p>(iv) the church tax; </p>
                    <p>(v) the tax withheld at source from interest; and</p>
                    <p>(vi) the tax withheld at source from non residents" income, (hereinafter referred to
      as "Finnish tax").</p>
                    <p>2. The Convention shall apply also to any identical or substantially similar taxes
      that are imposed after the date of signature of the Convention in addition to, or in place of,
      the existing taxes. The competent authorities of the Contracting States shall notify each
      other of any significant changes that have been made in their respective taxation
      laws.</p>
                </content>
            </article>
            <article eId="art_3">
                <num>Article 3</num>
                <heading>General Definitions</heading>
                <content>
                    <p>1. For the purposes of this Convention, unless the context otherwise
      requires:</p>
                    <p>a) the term "Canada", used in a geographical sense, means the territory of Canada,
      including</p>
                    <p>(i) any area beyond the territorial seas of Canada which, in accordance with
      international law and the laws of Canada, is an area in respect of which Canada may exercise
      rights with respect to the seabed and subsoil and their natural resources; and</p>
                    <p>(ii) the seas and airspace above every area referred to in clause (i) in respect of
      any activities carried on in connection with the exploration for or the exploitation of the
      natural resources referred to therein;</p>
                    <p>b) the term "Finland" means the Republic of Finland and, when used in a geographical
      sense, means the territory of the Republic of Finland, and any area adjacent to the
      territorial waters of the Republic of Finland within which, under the laws of Finland and in
      accordance with international law, the rights of Finland with respect to the exploration and
      exploitation of the natural resources of the seabed and its subsoil may be
      exercised;</p>
                    <p>c) the terms "a Contracting State" and "the other Contracting State" mean, as the
      context requires, Canada or Finland;</p>
                    <p>d) the term "person" includes an individual, a trust, a company, a partnership and any
      other body of persons;</p>
                    <p>e) the term "company" means any body corporate or any entity which is treated as a
      body corporate for tax purposes; </p>
                    <p>f) the term "enterprise" applies to the carrying on of any business;</p>
                    <p>g) 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;</p>
                    <p>h) the term "national", in relation to a Contracting State, means:</p>
                    <p>(i) any individual possessing the nationality or citizenship of that Contracting
      State; and</p>
                    <p>(ii) any legal person, partnership or association deriving its status as such from the
      laws in force in that Contracting State;</p>
                    <p>i) the term "international traffic" means any transport by a ship or aircraft operated
      by an enterprise of a Contracting State, except when the ship or aircraft is operated solely
      between places in the other Contracting State;</p>
                    <p>j) the term "tax" means Canadian tax or Finnish tax, as the context
      requires;</p>
                    <p>k) the term "competent authority" means:</p>
                    <p>(i) in the case of Canada, the Minister of National Revenue or the Minister"s
      authorized representative,</p>
                    <p>(ii) in the case of Finland, the Ministry of Finance or the Ministry"s authorized
      representative or the authority which is designated as competent authority by the
      Ministry.</p>
                    <p>l) the term "business" includes the performance of professional services and of other
      activities of an independent character.</p>
                    <p>2. As regards the application of the Convention at any time by a Contracting State,
      any term not defined therein shall, unless the context otherwise requires, have the meaning
      that it has at that time under the law of that State for the purposes of the taxes to which
      the Convention applies, any meaning under the applicable tax laws of that State prevailing
      over a meaning given to the term under other laws of that State.</p>
                </content>
            </article>
            <article eId="art_4">
                <num>Article 4</num>
                <heading>Resident</heading>
                <content>
                    <p>1. For the purposes of this Convention, the term "resident of a Contracting State"
      means:</p>
                    <p>a) any person who, under the laws of that State, is liable to tax therein by reason of
      the person"s domicile, residence, place of management or any other criterion of a similar
      nature but does not include any person who is liable to tax in that State in respect only of
      income from sources in that State; and</p>
                    <p>b) that State, or a political subdivision or local authority thereof, or a statutory
      body of that State or subdivision.</p>
                    <p>For the purposes of this paragraph the term "statutory body" means any legal entity of
      a public character created by the laws of a Contracting State in which no person other than
      the State itself or a political subdivision thereof has an interest.</p>
                    <p>2. Where by reason of the provisions of paragraph 1 an individual is a resident of
      both Contracting States, then the individual"s status shall be determined as
      follows:</p>
                    <p>a) the individual shall be deemed to be a resident only of the State in which the
      individual has a permanent home available; if the individual has a permanent home available in
      both States, the individual shall be deemed to be a resident only of the State with which the
      individual"s personal and economic relations are closer (centre of vital
      interests);</p>
                    <p>b) if the State in which the individual"s centre of vital interests is situated cannot
      be determined, or if there is not a permanent home available to the individual in either
      State, the individual shall be deemed to be a resident only of the State in which the
      individual has an habitual abode;</p>
                    <p>c) if the individual has an habitual abode in both States or in neither of them, the
      individual shall be deemed to be a resident only of the State of which the individual is a
      national; and</p>
                    <p>d) if the individual is a national of both States or of neither of them, the competent
      authorities of the Contracting States shall settle the question by mutual
      agreement.</p>
                    <p>3. Where by reason of the provisions of paragraph 1 a company is a resident of both
      Contracting States, then it shall be deemed to be a resident of the State in which it is
      incorporated or otherwise constituted.</p>
                    <p>4. Where by reason of the provisions of paragraph 1 a person other than an individual
      or a company is a resident of both Contracting States, the competent authorities of the
      Contracting States shall by mutual agreement endeavour to settle the question and to determine
      the mode of application of the Convention to such person. In the absence of such agreement,
      such persons shall not be entitled to claim any relief or exemption from tax provided by the
      Convention except to the extent and in such manner as may be agreed upon by the competent
      authorities.</p>
                </content>
            </article>
            <article eId="art_5">
                <num>Article 5</num>
                <heading>Permanent Establishment</heading>
                <content>
                    <p>1. For the purposes of this Convention, the term "permanent establishment" means a
      fixed place of business through which the business of an enterprise is wholly or partly
      carried on.</p>
                    <p>2. The term "permanent establishment" includes especially:</p>
                    <p>a) a place of management;</p>
                    <p>b) a branch;</p>
                    <p>c) an office;</p>
                    <p>d) a factory;</p>
                    <p>e) a workshop; and</p>
                    <p>f) a mine, an oil or gas well, a quarry or any other place relating to the exploration
      for or the exploitation of natural resources.</p>
                    <p>3. A building site or construction or installation project constitutes a permanent
      establishment only if it lasts more than twelve months.</p>
                    <p>4. Notwithstanding the preceding provisions of this Article, the term "permanent
      establishment" shall be deemed not to include:</p>
                    <p>a) the use of facilities solely for the purpose of storage, display or delivery of
      goods or merchandise belonging to the enterprise;</p>
                    <p>b) the maintenance of a stock of goods or merchandise belonging to the enterprise
      solely for the purpose of storage, display or delivery;</p>
                    <p>c) the maintenance of a stock of goods or merchandise belonging to the enterprise
      solely for the purpose of processing by another enterprise;</p>
                    <p>d) the maintenance of a fixed place of business solely for the purpose of purchasing
      goods or merchandise or of collecting information, for the enterprise;</p>
                    <p>e) the maintenance of a fixed place of business solely for the purpose of carrying on,
      for the enterprise, any other activity of a preparatory or auxiliary character;</p>
                    <p>f) the maintenance of a fixed place of business solely for any combination of
      activities mentioned in subparagraphs a) to e), provided that the overall activity of the
      fixed place of business resulting from this combination is of a preparatory or auxiliary
      character.</p>
                    <p>5. Notwithstanding the provisions of paragraphs 1 and 2, where a person other than an
      agent of an independent status to whom paragraph 6 applies is acting on behalf of an
      enterprise and has, and habitually exercises, in a Contracting State an authority to conclude
      contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent
      establishment in that State in respect of any activities which that person undertakes for the
      enterprise, unless the activities of such persons are limited to those mentioned in paragraph
      4 which, if exercised through a fixed place of business, would not make this fixed place of
      business a permanent establishment under the provisions of that paragraph.</p>
                    <p>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, provided that such persons are acting in the ordinary course of their
      business.</p>
                    <p>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.</p>
                </content>
            </article>
            <article eId="art_6">
                <num>Article 6</num>
                <heading>Income from Immovable Property</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State from immovable property
      (including income from agriculture or forestry) situated in the other Contracting State may be
      taxed in that other State.</p>
                    <p>2. For the purposes of this Convention, the term "immovable property" shall have the
      meaning which it has under the law of the Contracting State in which the property in question
      is situated. The term 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 and aircraft shall not be regarded as
      immovable property.</p>
                    <p>3. The provisions of paragraph 1 shall apply to income derived from the direct use,
      letting, or use in any other form of immovable property and to income from the alienation of
      such property.</p>
                    <p>4. Where the ownership of shares or other corporate rights in a company entitles the
      owner of such shares or corporate rights to the enjoyment of immovable property held by the
      company, the income from the direct use, letting, or use in any other form of such right to
      enjoyment may be taxed in the Contracting State in which the immovable property is
      situated.</p>
                    <p>5. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable
      property of an enterprise.</p>
                </content>
            </article>
            <article eId="art_7">
                <num>Article 7</num>
                <heading>Business Profits</heading>
                <content>
                    <p>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 or has carried 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.</p>
                    <p>2. Subject to the provisions of paragraph 3, 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 wholly independently with the enterprise of which it is a permanent
      establishment and with all other persons.</p>
                    <p>3. In determining the profits of a permanent establishment, there shall be allowed
      those deductible expenses which are incurred for the purposes of the permanent establishment
      including executive and general administrative expenses so incurred, whether in the State in
      which the permanent establishment is situated or elsewhere.</p>
                    <p>4. No profits shall be attributable to a permanent establishment by reason of the mere
      purchase by that permanent establishment of goods or merchandise for the
      enterprise.</p>
                    <p>5. 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.</p>
                    <p>6. Where profits include items of income 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.</p>
                </content>
            </article>
            <article eId="art_8">
                <num>Article 8</num>
                <heading>Shipping and Air Transport</heading>
                <content>
                    <p>1. Profits derived by an enterprise of a Contracting State from the operation of ships
      or aircraft in international traffic shall be taxable only in that State.</p>
                    <p>2. Notwithstanding the provisions of paragraph 1 and Article 7, profits derived from
      the operation of ships used principally to transport passengers or goods exclusively between
      places in a Contracting State may be taxed in that State.</p>
                    <p>3. The provisions of paragraphs 1 and 2 shall also apply to profits from the
      participation in a pool, a joint business or an international operating agency.</p>
                </content>
            </article>
            <article eId="art_9">
                <num>Article 9</num>
                <heading>Associated Enterprises</heading>
                <content>
                    <p>1. Where</p>
                    <p>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</p>
                    <p>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, </p>
                    <p>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.</p>
                    <p>2. Where a Contracting State includes in the profits of an enterprise of that State
      and taxes accordingly profits on which an enterprise of the other Contracting State has been
      charged to tax in that other State and the profits so included are profits which would have
      accrued to the enterprise of the first-mentioned State if the conditions made between the two
      enterprises had been those which would have been made between independent enterprises, then
      that other State shall make an appropriate adjustment to the amount of tax charged therein on
      those profits, where that other State considers the adjustment justified. In determining such
      adjustment, due regard shall be had to the other provisions of this Convention and the
      competent authorities of the Contracting States shall if necessary consult each
      other.</p>
                    <p>3. A Contracting State shall not change the profits of an enterprise in the
      circumstances referred to in paragraph 1 after six years from the end of the year in which the
      profits which would be subject to such change would have accrued to an enterprise of that
      State.</p>
                    <p>4. The provisions of paragraphs 2 and 3 shall not apply in the cause of fraud, wilful
      default or neglect.</p>
                </content>
            </article>
            <article eId="art_10">
                <num>Article 10</num>
                <heading>Dividends</heading>
                <content>
                    <p>1. Dividends paid by a company which is a resident of a Contracting State to a
      resident of the other Contracting State may be taxed in that other State.</p>
                    <p>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 laws of that State, but if
      the beneficial owner of the dividends is a resident of the other Contracting State, the tax so
      charged shall not exceed:</p>
                    <p>a) 5 per cent of the gross amount of the dividends if the beneficial owner is a
      company which owns at least 10 per cent of the voting stock in the company paying the
      dividends;</p>
                    <p>b) 15 per cent of the gross amount of the dividends in all other cases.</p>
                    <p>The provisions of this paragraph shall not affect the taxation of the company on the
      profits out of which the dividends are paid.</p>
                    <p>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 which is subject to
      the same taxation treatment as income from shares by the taxation law of the State of which
      the company making the distribution is a resident.</p>
                    <p>4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      dividends, being a resident of a Contracting State, carries on business in the other
      Contracting State of which the company paying the dividends is a resident, through a permanent
      establishment situated therein and the holding in respect of which the dividends are paid is
      effectively connected with such permanent establishment. In such case the provisions of
      Article 7 shall apply.</p>
                    <p>5. 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, except insofar as such dividends are paid to a resident of that
      other State or insofar as the holding in respect of which the dividends are paid is
      effectively connected with a permanent establishment situated in that other State, nor 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
      such other State.</p>
                    <p>6. Notwithstanding any provision in this Convention, Canada may impose on the earnings
      of a company attributable to permanent establishments in Canada, or on the earnings
      attributable to the alienation of immovable property situated in Canada by a company carrying
      on a trade in immovable property, a tax in addition to the tax which would be chargeable on
      the earnings of a company incorporated in Canada, provided that the rate of such additional
      tax so imposed shall not exceed 5 per cent of the amount of such earnings which have not been
      subjected to such additional tax in previous taxation years. For the purpose of this
      provision, the term "earnings" means the earnings attributable to the alienation of such
      immovable property situated in Canada as may be taxed by Canada under the provisions of
      Article 6 or of paragraph 1 of Article 13 as well as the profits attributable to a permanent
      establishment situated in Canada (including gains from the alienation of property forming part
      of the business property, referred to in paragraph 2 of Article 13, of such permanent
      establishments) in accordance with Article 7 in a year and previous years after deducting
      therefrom:</p>
                    <p>a) business losses attributable to such permanent establishments (including losses
      from the alienation of property forming part of the business property of such permanent
      establishments) in such year and previous years;</p>
                    <p>b) all taxes chargeable in Canada on such profits, other than the additional tax
      referred to herein;</p>
                    <p>c) the profits reinvested in Canada, provided that the amount of such deduction shall
      be determined in accordance with the existing provisions of the law of Canada regarding the
      computation of the allowance in respect of investment in property in Canada, and any
      subsequent modification of those provisions which shall not affect the general principle
      hereof; and</p>
                    <p>d) five hundred thousand Canadian dollars ($500,000) less any amount deducted under
      this subparagraph</p>
                    <p>(i) by the company; or</p>
                    <p>(ii) by a person related thereto from the same or a similar business as that carried
      on by the company.</p>
                </content>
            </article>
            <article eId="art_11">
                <num>Article 11</num>
                <heading>Interest</heading>
                <content>
                    <p>1. Interest arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such interest may also be taxed in the Contracting State in which it
      arises and according to the laws of that State, but if the beneficial owner of the interest is
      a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of
      the gross amount of the interest.</p>
                    <p>3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting
      State and paid to a resident of the other Contracting State who is the beneficial owner
      thereof shall be taxable only in that other State to the extent that such interest:</p>
                    <p>a) is a penalty charge for late payment;</p>
                    <p>b) is paid by the central bank of a Contracting State to the central bank of the other
      Contracting State; or</p>
                    <p>c) is paid by a purchasing enterprise to a selling enterprise in connection with the
      sale on credit of any equipment or merchandise, except where the sale is made between
      associated enterprises within the meaning of Article 9, subparagraph 1 a) or b).</p>
                    <p>4. Notwithstanding the provisions of paragraph 2:</p>
                    <p>a) interest arising in a Contracting State and paid in respect of indebtedness of the
      government of that State or of a political subdivision or a local authority thereof shall,
      provided that the interest is beneficially owned by a resident of the other Contracting State,
      be taxable only in that other State;</p>
                    <p>b) interest arising in Finland and paid to a resident of Canada shall be taxable only
      in Canada if it is paid in respect of a loan made, guaranteed or insured, or a credit
      extended, guaranteed or insured by Export Development Canada; and</p>
                    <p>c) interest arising in Canada and paid to a resident of Finland shall be taxable only
      in Finland if it is paid in respect of a loan made, guaranteed or insured, or a credit
      extended, guaranteed or insured by Finnvera or the Finnish Export Credit PLC.</p>
                    <p>5. The term "interest" as used in this Article means income from debt claims of every
      kind, whether or not secured by mortgage, and whether or not carrying a right to participate
      in the debtor"s profits, and in particular, income from government securities and income from
      bonds or debentures, including premiums and prizes attaching to such securities, bonds or
      debentures, as well as income assimilated to income from money lent by the taxation law of the
      State in which the income arises. However, the term "interest" does not include income dealt
      with in Article 8 or Article 10.</p>
                    <p>6. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      interest, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the interest arises, through a permanent establishment situated
      therein, and the debt claim in respect of which the interest is paid is effectively connected
      with such permanent establishment. In such case the provisions of Article 7 shall
      apply.</p>
                    <p>7. Interest shall be deemed to arise in a Contracting State when the payer is a
      resident of that State. Where, however, the person paying the interest, whether the payer is a
      resident of a Contracting State or not, has in a Contracting State a permanent establishment
      in connection with which the indebtedness on which the interest is paid was incurred, and such
      interest is borne by such permanent establishment, then such interest shall be deemed to arise
      in the State in which the permanent establishment is situated.</p>
                    <p>8. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the interest, 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 such case, the excess part of
      the payments shall remain taxable according to the laws of each Contracting State, due regard
      being had to the other provisions of this Convention.</p>
                </content>
            </article>
            <article eId="art_12">
                <num>Article 12</num>
                <heading>Royalties</heading>
                <content>
                    <p>1. Royalties arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such royalties may also be taxed in the Contracting State in which they
      arise, and according to the laws of that State, but if the beneficial owner of the royalties
      is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent
      of the gross amount of the royalties.</p>
                    <p>3. Notwithstanding the provisions of paragraph 2:</p>
                    <p>a) copyright royalties and other like payments in respect of the production or
      reproduction of any literary, dramatic, musical or artistic work (but not including royalties
      in respect of motion-picture films and works on film, videotape, or any other means of
      reproduction for use in connection with television) arising in a Contracting State and
      beneficially owned by a resident of the other Contracting State shall be taxable only in that
      other State;</p>
                    <p>b) royalties for the use of, or the right to use, computer software or any patent or
      for information concerning industrial, commercial or scientific experience (but not including
      any such royalty provided in connection with a rental or franchise agreement) arising in a
      Contracting State and paid to a resident of the other Contracting State who is the beneficial
      owner of the royalties shall be taxable only in that other State; and</p>
                    <p>c) royalties arising in a Contracting State and paid to the government of the other
      Contracting State shall be taxable only in that other State.</p>
                    <p>4. 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, patent, trade mark, design
      or model, plan, secret formula or process or other intangible property, or for the use of, or
      the right to use, industrial, commercial or scientific equipment, or for information
      concerning industrial, commercial or scientific experience, and includes payments of any kind
      in respect of motion-picture films and works on film, videotape, or any other means of
      reproduction for use in connection with television.</p>
                    <p>5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of
      the royalties, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the royalties arise, through a permanent establishment situated
      therein, and the right or property in respect of which the royalties are paid is effectively
      connected with such permanent establishment. In such case the provisions of Article 7 shall
      apply.</p>
                    <p>6. Royalties shall be deemed to arise in a Contracting State when the payer is a
      resident of that State. Where, however, the person paying the royalties, whether the payer is
      a resident of a Contracting State or not, has in a Contracting State a permanent establishment
      in connection with which the obligation to pay the royalties was incurred, and such royalties
      are borne by such permanent establishment, then such royalties shall be deemed to arise in the
      State in which the permanent establishment is situated.</p>
                    <p>7. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the royalties, 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
      such case, the excess part of the payments shall remain taxable according to the laws of each
      Contracting State, due regard being had to the other provisions of this Convention.</p>
                </content>
            </article>
            <article eId="art_13">
                <num>Article 13</num>
                <heading>Capital Gains</heading>
                <content>
                    <p>1. Gains derived by a resident of a Contracting State from the alienation of immovable
      property situated in the other Contracting State may be taxed in that other State.</p>
                    <p>2. 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, including such gains from the alienation of such a permanent establishment
      (alone or with the whole enterprise) may be taxed in that other State.</p>
                    <p>3. Gains derived by a resident of a Contracting State from the alienation of ships or
      aircraft operated in international traffic or movable property pertaining to the operation of
      such ships or aircraft, shall be taxable only in that State.</p>
                    <p>
                        <embeddedStructure class="mli-replaced">
                            <p>
                                <authorialNote>
                                    <p>[REPLACED by paragraph 4 of Article 9 of the MLI]</p>
                                </authorialNote>
                            </p>
                            <p>[4. Gains derived by a resident of a Contracting State from the alienation
        of:</p>
                            <p>a) shares or other corporate rights in a company, the property of which consists
        principally of immovable property situated in a Contracting State; or</p>
                            <p>b) an interest in a partnership or a trust, the property of which consists
        principally from immovable property situated in a Contracting State, may be taxed in that
        State.</p>
                            <p>For the purposes of this paragraph the term "immovable property" shall not include
        property, other than rental property, in which the business of the company, partnership or
        trust is carried on; however, this term shall include shares or other corporate rights in a
        company described in subparagraph a) above and an interest in a partnership or a trust
        described in subparagraph b) above.]</p>
                        </embeddedStructure>
                    </p>
                    <p>
                        <embeddedStructure class="mli-replacement">
                            <p>
                                <authorialNote>
                                    <p>
                                        The following paragraph 4 of Article 9 of the MLI replaces paragraph 4 of
        Article 13 of this Convention:
                                        <authorialNote marker="2" placement="bottom">
                                            <p>In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of
            the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the application
            of this Convention by the Republic of Finland: </p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            non-residents, where the event giving rise to such taxes occurs on or after 1 January
            2024; and</p>
                                            <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2024;</p>
                                            <p>and,</p>
                                            <p>In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of
            the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the application
            of the Convention by Canada: </p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            non-residents, where the event giving rise to such taxes occurs on or after 1 January
            2024; and</p>
                                            <p>b) with respect to all other taxes levied by Canada, for taxes levied with
            respect to taxable periods beginning on or after 1 January 2024.</p>
                                        </authorialNote>
                                    </p>
                                </authorialNote>
                            </p>
                            <article>
                                <num>ARTICLE 9 OF THE MLI – CAPITAL GAINS FROM ALIENATION OF SHARES OR INTERESTS OF ENTITIES DERIVING THEIR VALUE PRINCIPALLY FROM IMMOVABLE PROPERTY</num>
                                <content>
                                    <p>
                                        For purposes of [
                                        <i>the Convention</i>
                                        ], gains derived by a
          resident of a [
                                        <i>Contracting State</i>
                                        ] from the alienation of shares or
          comparable interests, such as interests in a partnership or trust, may be taxed in the
          other [
                                        <i>Contracting State</i>
                                        ] if, at any time during the 365 days
          preceding the alienation, these shares or comparable interests derived more than 50 per
          cent of their value directly or indirectly from immovable property (real property)
          situated in that other [
                                        <i>Contracting State</i>
                                        ].
                                    </p>
                                </content>
                            </article>
                        </embeddedStructure>
                    </p>
                    <p>5. Gains from the alienation of any property other than that referred to in paragraphs
      1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator is a
      resident.</p>
                    <p>6. Where a resident of a Contracting State alienates property in the course of a
      corporate or other organization, reorganization, amalgamation, division or similar transaction
      and profit, gain or income with respect to such alienation is not recognized for the purpose
      of taxation in that State, if requested to do so by the person who acquires the property, the
      competent authority of the other Contracting State may agree, in order to avoid double
      taxation and subject to terms and conditions satisfactory to such competent authority, to
      defer the recognition of the profit, gain or income with respect to such property for the
      purpose of taxation in that other State until such time and in such manner as may be
      stipulated in the agreement.</p>
                    <p>7. The provisions of paragraph 5 shall not affect the right of either of the
      Contracting States to levy, according to its law, a tax on gains derived by an individual who
      is a resident of the other Contracting State, from the alienation of any property (other than
      property to which paragraph 8 applies) if the alienator:</p>
                    <p>a) is a national of the first mentioned State or was a resident of that State for ten
      years or more prior to the alienation of the property; and</p>
                    <p>b) was a resident of that first-mentioned State at any time during the five years
      immediately preceding such alienation.</p>
                    <p>8. Where an individual ceases to be a resident of a Contracting State and by reason
      thereof is treated for the purposes of taxation by that State as having alienated property and
      is taxed in that State and immediately thereafter becomes a resident of the other Contracting
      State, the other Contracting State may tax gains in respect of the property only to the extent
      that such gains had not accrued before the individual ceased to be a resident of the
      first-mentioned State. However, this provision shall not apply to property, any gain from
      which that other State could have taxed in accordance with the provisions of this Article,
      other than this paragraph, if the individual had realized the gain before becoming a resident
      of that other State.</p>
                </content>
            </article>
            <article eId="art_14">
                <num>Article 14</num>
                <heading>Income from Employment</heading>
                <content>
                    <p>1. Subject to the provisions of Articles 15, 17 and 18, 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.</p>
                    <p>2. Notwithstanding the provisions of paragraph 1, 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:</p>
                    <p>a) the recipient is present in the other State for a period or periods not exceeding
      in the aggregate 183 days within any twelve-month period commencing or ending in the calendar
      year concerned; and</p>
                    <p>b) the remuneration is paid by, or on behalf of, an employer who is not a resident of
      the other State; and</p>
                    <p>c) the remuneration is not borne by a permanent establishment which the employer has
      in the other State.</p>
                    <p>3. Notwithstanding the preceding provisions of this Article, remuneration derived in
      respect of an employment exercised aboard a ship or aircraft operated in international traffic
      by an enterprise of a Contracting State shall be taxable only in that State. However, if the
      remuneration is derived by a resident of the other Contracting State, it may also be taxed in
      that other State.</p>
                </content>
            </article>
            <article eId="art_15">
                <num>Article 15</num>
                <heading>Directors' Fees</heading>
                <content>
                    <p>Directors' fees and other similar payments derived by a resident of a Contracting
      State in his capacity as a member of the board of directors or a similar organ of a company
      which is a resident of the other Contracting State may be taxed in that other
      State.</p>
                </content>
            </article>
            <article eId="art_16">
                <num>Article 16</num>
                <heading>Artistes and Sportspersons</heading>
                <content>
                    <p>1. Notwithstanding the provisions of Articles 7 and 14, income derived by a resident
      of a Contracting State as an entertainer, such as a theatre, motion-picture, radio or
      television artiste, or a musician, or as a sportsperson, from that individual"s personal
      activities as such exercised in the other Contracting State, may be taxed in that other
      State.</p>
                    <p>2. Where income in respect of personal activities exercised by an entertainer or a
      sportsperson in that individual"s capacity as such accrues not to the entertainer or
      sportsperson personally but to another person, that income may, notwithstanding the provisions
      of Articles 7 and 14, be taxed in the Contracting State in which the activities of the
      entertainer or sportsperson are exercised.</p>
                    <p>3. The provisions of paragraph 2 shall not apply if it is established that neither the
      entertainer or the sportsperson nor persons related thereto, participate directly or
      indirectly in the profits of the person referred to in that paragraph.</p>
                </content>
            </article>
            <article eId="art_17">
                <num>Article 17</num>
                <heading>Pensions and Annuities</heading>
                <content>
                    <p>1. Pensions and annuities arising in a Contracting State and paid to a resident of the
      other Contracting State may be taxed in that other State.</p>
                    <p>2. Pensions arising in a Contracting State and paid to a resident of the other
      Contracting State may also be taxed in the State in which they arise, and according to the
      laws of that State. However, in the case of periodic pension payments, the tax so charged
      shall not exceed 20 per cent of the gross amount of the payment.</p>
                    <p>3. Annuities arising in a Contracting State and paid to a resident of the other
      Contracting State may also be taxed in the State in which they arise, and according to the
      laws of that State, but the tax so charged shall not exceed 15 per cent of the portion thereof
      that is subject to tax in that State. However, this limitation does not apply to lump-sum
      payments arising on the surrender, cancellation, redemption, sale or other alienation of an
      annuity, or to payments of any kind under an annuity contract the cost of which was
      deductible, in whole or in part, in computing the income of any person who acquired the
      contract.</p>
                    <p>4. Notwithstanding any provision of this Convention, war veterans pensions and
      allowances arising in a Contracting State and paid to a resident of the other Contracting
      State shall be exempt from tax in that other State to the extent that they would be exempt
      from tax if received by a resident of the first-mentioned State.</p>
                    <p>5. The term "annuity" as used in this Article means a stated sum payable periodically
      to an individual at stated times during the individual"s 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 (other than services rendered).</p>
                </content>
            </article>
            <article eId="art_18">
                <num>Article 18</num>
                <heading>Government Service</heading>
                <content>
                    <p>1. a) Salaries, wages and other similar remuneration, other than a pension, paid by a
      Contracting State or a political subdivision or a local authority thereof to an individual in
      respect of services rendered to that State or subdivision or authority shall be taxable only
      in that State.</p>
                    <p>b) However, such salaries, wages and other similar remuneration shall be taxable only
      in the other Contracting State if the services are rendered in that State and the individual
      is a resident of that State who:</p>
                    <p>(i) is a national of that State; or</p>
                    <p>(ii) did not become a resident of that State solely for the purpose of rendering the
      services.</p>
                    <p>2. The provisions of Articles 14, 15 and 16 shall apply to salaries, wages and other
      similar remuneration in respect of services rendered in connection with a business carried on
      by a Contracting State or a political subdivision or a local authority thereof.</p>
                </content>
            </article>
            <article eId="art_19">
                <num>Article 19</num>
                <heading>Students and Apprentices</heading>
                <content>
                    <p>Payments which a student, apprentice or business trainee 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 State solely for the purpose of that individual"s education or
      training receives for the purpose of that individual"s maintenance, education or training
      shall not be taxed in that State, provided that such payments arise from sources outside that
      State.</p>
                </content>
            </article>
            <article eId="art_20">
                <num>Article 20</num>
                <heading>Other Income</heading>
                <content>
                    <p>1. Subject to the provisions of paragraph 2, items of income of a resident of a
      Contracting State not dealt with in the foregoing Articles of this Convention shall be taxable
      only in that State.</p>
                    <p>2. However, if such income is derived by a resident of a Contracting State from
      sources in the other Contracting State, such income may also be taxed in the State in which it
      arises, and according to the law of that State. However, in the case of income from a trust,
      the tax so charged shall, provided that the income is taxable in the Contracting State in
      which the recipient resides, not exceed 15 per cent of the gross amount of the
      income.</p>
                    <p>3. For the purposes of this Article, a trust does not include an arrangement whereby
      the contributions made to the trust are deductible for the purposes of taxation in
      Canada.</p>
                </content>
            </article>
            <article eId="art_21">
                <num>Article 21</num>
                <heading>Elimination of Double Taxation</heading>
                <content>
                    <p>1. In the case of Canada, double taxation shall be eliminated as follows:</p>
                    <p>a) subject to the existing provisions of the law of Canada regarding the deduction
      from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent
      modification of those provisions - which shall not affect the general principle hereof - and
      unless a greater deduction or relief is provided under the laws of Canada, tax payable in
      Finland on profits, income or gains arising in Finland shall be deducted from any Canadian tax
      payable in respect of such profits, income or gains.</p>
                    <p>b) subject to the existing provisions of the law of Canada regarding the allowance as
      a credit against Canadian tax of tax payable in a territory outside Canada and to any
      subsequent modification of those provisions - which shall not affect the general principle
      hereof - where a company which is a resident of Finland pays a dividend to a company which is
      a resident of Canada and which controls directly or indirectly at least 10 per cent of the
      voting power in the first-mentioned company, the credit shall take into account the tax
      payable in Finland by that first-mentioned company in respect of the profits out of which such
      dividend is paid; and</p>
                    <p>c) where in accordance with any provision of the Convention income derived by a
      resident of Canada is exempt from tax in Canada, Canada may nevertheless, in calculating the
      amount of tax on other income, take into account the exempted income.</p>
                    <p>2. Subject to the provisions of Finnish law regarding the elimination of international
      double taxation (which shall not affect the general principle hereof) double taxation shall be
      eliminated in Finland as follows:</p>
                    <p>a) Where a resident of Finland derives income which, in accordance with the provisions
      of this Convention, may be taxed in Canada, Finland shall, subject to the provisions of
      subparagraph b), allow as a deduction from the Finnish tax of that person, an amount equal to
      the Canadian tax paid under Canadian law and in accordance with the Convention, as computed by
      reference to the same income by reference to which the Finnish tax is computed.</p>
                    <p>b) Dividends paid by a company which is a resident of Canada to a company which is a
      resident of Finland and which controls directly at least 10 per cent of the voting power in
      the company paying the dividends shall be exempt from Finnish tax.</p>
                    <p>c) Where in accordance with any provision of the Convention income derived by a
      resident of Finland is exempt from tax in Finland, Finland may nevertheless, in calculating
      the amount of tax on the remaining income of such resident, take into account the exempted
      income.</p>
                    <p>3. For the purposes of this Article, profits, income or gains of a resident of a
      Contracting State which are taxed in the other Contracting State in accordance with the
      Convention shall be deemed to arise from sources in that other State.</p>
                </content>
            </article>
            <article eId="art_22">
                <num>Article 22</num>
                <heading>Non-Discrimination</heading>
                <content>
                    <p>1. Nationals of a Contracting State shall not be subjected in the other Contracting
      State to any taxation or any requirement connected therewith which is more burdensome than the
      taxation and connected requirements to which nationals of that other State in the same
      circumstances are or may be subjected.</p>
                    <p>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.</p>
                    <p>3. Nothing in this Article shall be construed as obliging a Contracting State to grant
      to residents of the other Contracting State personal allowances, reliefs and reductions for
      taxation purposes on account of civil status or family responsibilities which it grants to its
      own residents.</p>
                    <p>4. In this Article, the term "taxation" means taxes which are the subject of this
      Convention.</p>
                </content>
            </article>
            <article eId="art_23">
                <num>Article 23</num>
                <heading>Mutual Agreement Procedure</heading>
                <content>
                    <p>1. Where a person considers that the actions of one or both of the Contracting States
      result or will result for that person in taxation not in accordance with the provisions of
      this Convention, that person may, irrespective of the remedies provided by the domestic law of
      these States, address to the competent authority of the Contracting State of which that person
      is a resident an application in writing stating the grounds for claiming the revision of such
      taxation. To be admissible, the said application must be submitted within three years from the
      first notification of the action which gives rise to taxation not in accordance with the
      Convention.</p>
                    <p>2. The competent authority referred to in paragraph 1 shall endeavour, if the
      objection appears to it to be justified and if it is not itself able to arrive at a
      satisfactory 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 which is not in
      accordance with the Convention.</p>
                    <p>3. A Contracting State shall not after six years from the end of the taxable period in
      which the income concerned has accrued, increase the tax base of a resident of either of the
      Contracting States by including therein items of income which have also been charged to tax in
      the other Contracting State. This paragraph shall not apply in the case of fraud, wilful
      default or neglect.</p>
                    <p>4. 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. In particular, the competent authorities of the Contracting State may consult
      together to endeavour to agree:</p>
                    <p>a) to the same attribution of profits to a resident of a Contracting State and its
      permanent establishment situated in the other Contracting State;</p>
                    <p>b) to the same allocation of income between a resident of a Contracting State and any
      associated person provided for in Article 9.</p>
                    <p>5. The competent authorities of the Contracting States may consult together for the
      elimination of double taxation in cases not provided for in the Convention.</p>
                </content>
            </article>
            <p>
                <embeddedStructure class="mli-addition">
                    <p>
                        <authorialNote>
                            <p>
                                The following Part VI of the MLI applies to this
          Convention:
                                <authorialNote marker="3" placement="bottom">
                                    <p>In accordance with paragraph 1 of Article 36 of the
          MLI, the provisions of Part VI (Arbitration) of the MLI has effect with respect to this
          Convention: </p>
                                    <p>a) with respect to cases presented to the competent
          authority of a Contracting State on or after 1 December 2019; and </p>
                                    <p>b)
          with respect to cases presented to the competent authority of a Contracting State prior to
          1 December 2019, on the date when both Contracting States have notified the
          Secretary-General of the OECD that they have reached mutual agreement pursuant to
          paragraph 10 of Article 19 of the MLI (Mandatory Binding Arbitration), along with
          information regarding the date or dates on which such cases shall be considered to have
          been presented to the competent authority of a Contracting State (as described in
          subparagraph a) of paragraph 1 of Article 19 of the MLI (Mandatory Binding Arbitration))
          according to the terms of that mutual agreement.</p>
                                    <p>However, the scope of cases
        eligible for arbitration under the provisions of Part VI of the MLI is limited due to
        reservations formulated in accordance with subparagraph a) of paragraph 2 of Article 28 of
        the MLI by the Contracting States. See these reservations at the end of this
        box.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <chapter>
                        <num>PART VI. ARBITRATION</num>
                        <article>
                            <num>Article 19 (Mandatory Binding Arbitration) of the MLI</num>
                            <content>
                                <p>1. Where:</p>
                                <p>
                                    a) under [
                                    <i>paragraph 1 of Article 23 of this Convention</i>
                                    ], a
          person has presented a case to the competent authority of a [
                                    <i>Contracting
            State</i>
                                    ] on the basis that the actions of one or both of the
            [
                                    <i>Contracting States</i>
                                    ] have resulted for that person in taxation
          not in accordance with the provisions of [
                                    <i>the Convention</i>
                                    ];
          and
                                </p>
                                <p>
                                    b) the competent authorities are unable to reach an agreement to resolve that case
          pursuant to [
                                    <i>paragraph 2 of Article 23 of the Convention</i>
                                    ], within a
          period of two years beginning on the start date referred to in paragraph 8 or 9
            [
                                    <i>of Article 19 of the MLI</i>
                                    ], as the case may be (unless, prior to
          the expiration of that period the competent authorities of the [
                                    <i>Contracting
            States</i>
                                    ] have agreed to a different time period with respect to that case and
          have notified the person who presented the case of such agreement),
                                </p>
                                <p>
                                    any unresolved issues arising from the case shall, if the person so requests in
          writing, be submitted to arbitration in the manner described in [
                                    <i>Part VI of the
            MLI</i>
                                    ], according to any rules or procedures agreed upon by the competent
          authorities of the [
                                    <i>Contracting States</i>
                                    ] pursuant to the provisions
          of paragraph 10 [
                                    <i>of Article 19 of the MLI</i>
                                    ].
                                </p>
                                <p>
                                    2. Where a competent authority has suspended the mutual agreement procedure
          referred to in paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ] because a
          case with respect to one or more of the same issues is pending before court or
          administrative tribunal, the period provided in subparagraph b) of paragraph 1
            [
                                    <i>of Article 19 of the MLI</i>
                                    ] will stop running until either a final
          decision has been rendered by the court or administrative tribunal or the case has been
          suspended or withdrawn. In addition, where a person who presented a case and a competent
          authority have agreed to suspend the mutual agreement procedure, the period provided in
          subparagraph b) of paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ] will stop
          running until the suspension has been lifted.
                                </p>
                                <p>
                                    3. Where both competent authorities agree that a person directly affected by the
          case has failed to provide in a timely manner any additional material information
          requested by either competent authority after the start of the period provided in
          subparagraph b) of paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ], the
          period provided in subparagraph b) of paragraph 1 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ] shall be extended for an amount of time equal to the period beginning
          on the date by which the information was requested and ending on the date on which that
          information was provided.
                                </p>
                                <p>
                                    4. a) The arbitration decision with respect to the issues submitted to arbitration
          shall be implemented through the mutual agreement concerning the case referred to in
          paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ]. The arbitration decision
          shall be final.
                                </p>
                                <p>
                                    b) The arbitration decision shall be binding on both [
                                    <i>Contracting
            States</i>
                                    ] except in the following cases:
                                </p>
                                <p>i) if a person directly affected by the case does not accept the mutual agreement
          that implements the arbitration decision. In such a case, the case shall not be eligible
          for any further consideration by the competent authorities. The mutual agreement that
          implements the arbitration decision on the case shall be considered not to be accepted by
          a person directly affected by the case if any person directly affected by the case does
          not, within 60 days after the date on which notification of the mutual agreement is sent
          to the person, withdraw all issues resolved in the mutual agreement implementing the
          arbitration decision from consideration by any court or administrative tribunal or
          otherwise terminate any pending court or administrative proceedings with respect to such
          issues in a manner consistent with that mutual agreement.</p>
                                <p>
                                    ii) if a final decision of the courts of one of the [
                                    <i>Contracting
            States</i>
                                    ] holds that the arbitration decision is invalid. In such a case, the
          request for arbitration under paragraph 1 [
                                    <i>of Article 19 of the
          MLI</i>
                                    ] shall be considered not to have been made, and the arbitration process
          shall be considered not to have taken place (except for the purposes of Articles 21
          (Confidentiality of Arbitration Proceedings) and 25 (Costs of Arbitration Proceedings)
            [
                                    <i>of the MLI</i>
                                    ]). In such a case, a new request for arbitration may
          be made unless the competent authorities agree that such a new request should not be
          permitted.
                                </p>
                                <p>iii) if a person directly affected by the case pursues litigation on the issues
          which were resolved in the mutual agreement implementing the arbitration decision in any
          court or administrative tribunal.</p>
                                <p>
                                    5. The competent authority that received the initial request for a mutual
          agreement procedure as described in subparagraph a) of paragraph 1 [
                                    <i>of Article
            19 of the MLI</i>
                                    ] shall, within two calendar months of receiving the
          request:
                                </p>
                                <p>a) send a notification to the person who presented the case that it has received
          the request; and</p>
                                <p>
                                    b) send a notification of that request, along with a copy of the request, to the
          competent authority of the other [
                                    <i>Contracting State</i>
                                    ].
                                </p>
                                <p>
                                    6. Within three calendar months after a competent authority receives the request
          for a mutual agreement procedure (or a copy thereof from the competent authority of the
          other [
                                    <i>Contracting State</i>
                                    ]) it shall either:
                                </p>
                                <p>a) notify the person who has presented the case and the other competent authority
          that it has received the information necessary to undertake substantive consideration of
          the case; or</p>
                                <p>b) request additional information from that person for that purpose.</p>
                                <p>
                                    7. Where pursuant to subparagraph b) of paragraph 6 [
                                    <i>of Article 19 of
            the MLI</i>
                                    ], one or both of the competent authorities have requested from the
          person who presented the case additional information necessary to undertake substantive
          consideration of the case, the competent authority that requested the additional
          information shall, within three calendar months of receiving the additional information
          from that person, notify that person and the other competent authority either:
                                </p>
                                <p>a) that it has received the requested information; or</p>
                                <p>b) that some of the requested information is still missing.</p>
                                <p>
                                    8. Where neither competent authority has requested additional information pursuant
          to subparagraph b) of paragraph 6 [
                                    <i>of Article 19 of the MLI</i>
                                    ], the
          start date referred to in paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ]
          shall be the earlier of:
                                </p>
                                <p>
                                    a) the date on which both competent authorities have notified the person who
          presented the case pursuant to subparagraph a) of paragraph 6 [
                                    <i>of Article 19 of
            the MLI</i>
                                    ]; and
                                </p>
                                <p>
                                    b) the date that is three calendar months after the notification to the competent
          authority of the other [
                                    <i>Contracting State</i>
                                    ] pursuant to subparagraph
          b) of paragraph 5 [
                                    <i>of Article 19 of the MLI</i>
                                    ].
                                </p>
                                <p>
                                    9. Where additional information has been requested pursuant to subparagraph b) of
          paragraph 6 [
                                    <i>of Article 19 of the MLI</i>
                                    ], the start date referred to
          in paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ] shall be the earlier
          of:
                                </p>
                                <p>
                                    a) the latest date on which the competent authorities that requested additional
          information have notified the person who presented the case and the other competent
          authority pursuant to subparagraph a) of paragraph 7 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ]; and
                                </p>
                                <p>b) the date that is three calendar months after both competent authorities have
          received all information requested by either competent authority from the person who
          presented the case.</p>
                                <p>
                                    If, however, one or both of the competent authorities send the notification
          referred to in subparagraph b) of paragraph 7 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ], such notification shall be treated as a request for additional
          information under subparagraph b) of paragraph 6 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ].
                                </p>
                                <p>
                                    10. The competent authorities of the [
                                    <i>Contracting States</i>
                                    ]
          shall by mutual agreement pursuant to [
                                    <i>Article 23 of the
          Convention</i>
                                    ] settle the mode of application of the provisions contained in
            [
                                    <i>Part VI of the MLI</i>
                                    ], including the minimum information necessary
          for each competent authority to undertake substantive consideration of the case. Such an
          agreement shall be concluded before the date on which unresolved issues in a case are
          first eligible to be submitted to arbitration and may be modified from time to time
          thereafter.
                                </p>
                                <p>
                                    12. [
                                    <i>Notwithstanding</i>
                                    ] the other provisions of
            [
                                    <i>Article 19 of the MLI</i>
                                    ]:
                                </p>
                                <p>
                                    a) any unresolved issue arising from a mutual agreement procedure case otherwise
          within the scope of the arbitration process provided for by [
                                    <i>the
            MLI</i>
                                    ] shall not be submitted to arbitration, if a decision on this issue has
          already been rendered by a court or administrative tribunal of either
            [
                                    <i>Contracting State</i>
                                    ];
                                </p>
                                <p>
                                    b) if, at any time after a request for arbitration has been made and before the
          arbitration panel has delivered its decision to the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ], a decision concerning the issue is rendered
          by a court or administrative tribunal of one of the [
                                    <i>Contracting
            States</i>
                                    ], the arbitration process shall terminate.
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 20 (Appointment of Arbitrators) of the MLI</num>
                            <content>
                                <p>
                                    1. Except to the extent that the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ] mutually agree on different rules,
          paragraphs 2 through 4 [
                                    <i>of Article 20 of the MLI</i>
                                    ] shall apply for
          the purposes of [
                                    <i>Part VI of the MLI</i>
                                    ].
                                </p>
                                <p>2. The following rules shall govern the appointment of the members of an
          arbitration panel:</p>
                                <p>a) The arbitration panel shall consist of three individual members with expertise
          or experience in international tax matters.</p>
                                <p>
                                    b) Each competent authority shall appoint one panel member within 60 days of the
          date of the request for arbitration under paragraph 1 of Article 19 [
                                    <i>of the
            MLI</i>
                                    ]. The two panel members so appointed shall, within 60 days of the latter
          of their appointments, appoint a third member who shall serve as Chair of the arbitration
          panel. The Chair shall not be a national or resident of either [
                                    <i>Contracting
            State</i>
                                    ].
                                </p>
                                <p>
                                    c) Each member appointed to the arbitration panel must be impartial and
          independent of the competent authorities, tax administrations, and ministries of finance
          of the [
                                    <i>Contracting States</i>
                                    ] and of all persons directly affected by
          the case (as well as their advisors) at the time of accepting an appointment, maintain his
          or her impartiality and independence throughout the proceedings, and avoid any conduct for
          a reasonable period of time thereafter which may damage the appearance of impartiality and
          independence of the arbitrators with respect to the proceedings.
                                </p>
                                <p>
                                    3. In the event that the competent authority of a [
                                    <i>Contracting
            State</i>
                                    ] fails to appoint a member of the arbitration panel in the manner and
          within the time periods specified in paragraph 2 [
                                    <i>of Article 20 of the
            MLI</i>
                                    ] or agreed to by the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ], a member shall be appointed on behalf of
          that competent authority by the highest ranking official of the Centre for Tax Policy and
          Administration of the Organisation for Economic Co-operation and Development that is not a
          national of either [
                                    <i>Contracting State</i>
                                    ].
                                </p>
                                <p>
                                    4. If the two initial members of the arbitration panel fail to appoint the Chair
          in the manner and within the time periods specified in paragraph 2 [
                                    <i>of Article
            20 of the MLI</i>
                                    ] or agreed to by the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ], the Chair shall be appointed by the highest
          ranking official of the Centre for Tax Policy and Administration of the Organisation for
          Economic Co-operation and Development that is not a national of either
            [
                                    <i>Contracting State</i>
                                    ].
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 21 (Confidentiality of Arbitration Proceedings) of the MLI</num>
                            <content>
                                <p>
                                    1. Solely for the purposes of the application of the provisions of
            [
                                    <i>Part VI of the MLI</i>
                                    ] and of the provisions of [
                                    <i>the
            Convention</i>
                                    ] and of the domestic laws of the [
                                    <i>Contracting
            States</i>
                                    ] related to the exchange of information, confidentiality, and
          administrative assistance, members of the arbitration panel and a maximum of three staff
          per member (and prospective arbitrators solely to the extent necessary to verify their
          ability to fulfil the requirements of arbitrators) shall be considered to be persons or
          authorities to whom information may be disclosed. Information received by the arbitration
          panel or prospective arbitrators and information that the competent authorities receive
          from the arbitration panel shall be considered information that is exchanged under the
          provisions of [
                                    <i>the Convention</i>
                                    ] related to the exchange of
          information and administrative assistance.
                                </p>
                                <p>
                                    2. The competent authorities of the [
                                    <i>Contracting States</i>
                                    ]
          shall ensure that members of the arbitration panel and their staff agree in writing, prior
          to their acting in an arbitration proceeding, to treat any information relating to the
          arbitration proceeding consistently with the confidentiality and nondisclosure obligations
          described in the provisions of [
                                    <i>the Convention</i>
                                    ] related to exchange
          of information and administrative assistance and under the applicable laws of the
            [
                                    <i>Contracting States</i>
                                    ].
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 22 (Resolution of a Case Prior to the Conclusion of the Arbitration) of the MLI</num>
                            <content>
                                <p>
                                    For the purposes of [
                                    <i>Part VI of the MLI</i>
                                    ] and the provisions
          of [
                                    <i>the Convention</i>
                                    ] that provide for resolution of cases through
          mutual agreement, the mutual agreement procedure, as well as the arbitration proceeding,
          with respect to a case shall terminate if, at any time after a request for arbitration has
          been made and before the arbitration panel has delivered its decision to the competent
          authorities of the [
                                    <i>Contracting States</i>
                                    ]:
                                </p>
                                <p>
                                    a) the competent authorities of the [
                                    <i>Contracting States</i>
                                    ]
          reach a mutual agreement to resolve the case; or
                                </p>
                                <p>b) the person who presented the case withdraws the request for arbitration or the
          request for a mutual agreement procedure.</p>
                            </content>
                        </article>
                        <article>
                            <num>Article 23 (Type of Arbitration Process) of the MLI</num>
                            <content>
                                <p>
                                    1. Except to the extent that the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ] mutually agree on different rules, the
          following rules shall apply with respect to an arbitration proceeding pursuant to
            [
                                    <i>Part VI of the MLI</i>
                                    ]:
                                </p>
                                <p>
                                    a) After a case is submitted to arbitration, the competent authority of each
            [
                                    <i>Contracting State</i>
                                    ] shall submit to the arbitration panel, by a
          date set by agreement, a proposed resolution which addresses all unresolved issue(s) in
          the case (taking into account all agreements previously reached in that case between the
          competent authorities of the [
                                    <i>Contracting States</i>
                                    ]). The proposed
          resolution shall be limited to a disposition of specific monetary amounts (for example, of
          income or expense) or, where specified, the maximum rate of tax charged pursuant to
            [
                                    <i>the Convention</i>
                                    ], for each adjustment or similar issue in the
          case. In a case in which the competent authorities of the [
                                    <i>Contracting
            States</i>
                                    ] have been unable to reach agreement on an issue regarding the
          conditions for application of a provision of [
                                    <i>the Convention</i>
                                    ]
          (hereinafter referred to as a “threshold question”), such as whether an individual is a
          resident or whether a permanent establishment exists, the competent authorities may submit
          alternative proposed resolutions with respect to issues the determination of which is
          contingent on resolution of such threshold questions.
                                </p>
                                <p>
                                    b) The competent authority of each [
                                    <i>Contracting State</i>
                                    ] may
          also submit a supporting position paper for consideration by the arbitration panel. Each
          competent authority that submits a proposed resolution or supporting position paper shall
          provide a copy to the other competent authority by the date on which the proposed
          resolution and supporting position paper were due. Each competent authority may also
          submit to the arbitration panel, by a date set by agreement, a reply submission with
          respect to the proposed resolution and supporting position paper submitted by the other
          competent authority. A copy of any reply submission shall be provided to the other
          competent authority by the date on which the reply submission was due.
                                </p>
                                <p>
                                    c) The arbitration panel shall select as its decision one of the proposed
          resolutions for the case submitted by the competent authorities with respect to each issue
          and any threshold questions, and shall not include a rationale or any other explanation of
          the decision. The arbitration decision will be adopted by a simple majority of the panel
          members. The arbitration panel shall deliver its decision in writing to the competent
          authorities of the [
                                    <i>Contracting States</i>
                                    ]. The arbitration decision
          shall have no precedential value.
                                </p>
                                <p>
                                    5. Prior to the beginning of arbitration proceedings, the competent authorities of
          the [
                                    <i>Contracting States</i>
                                    ] shall ensure that each person that
          presented the case and their advisors agree in writing not to disclose to any other person
          any information received during the course of the arbitration proceedings from either
          competent authority or the arbitration panel. The mutual agreement procedure under
            [
                                    <i>the Convention</i>
                                    ], as well as the arbitration proceeding under
            [
                                    <i>Part VI of the MLI</i>
                                    ], with respect to the case shall terminate
          if, at any time after a request for arbitration has been made and before the arbitration
          panel has delivered its decision to the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ], a person that presented the case or one of
          that person’s advisors materially breaches that agreement.
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 25 (Costs of Arbitration Proceedings) of the MLI</num>
                            <content>
                                <p>
                                    In an arbitration proceeding under [
                                    <i>Part VI of the MLI</i>
                                    ],
          the fees and expenses of the members of the arbitration panel, as well as any costs
          incurred in connection with the arbitration proceedings by the [
                                    <i>Contracting
            States</i>
                                    ], shall be borne by the [
                                    <i>Contracting States</i>
                                    ]
          in a manner to be settled by mutual agreement between the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ]. In the absence of such agreement, each
            [
                                    <i>Contracting State</i>
                                    ] shall bear its own expenses and those of its
          appointed panel member. The cost of the chair of the arbitration panel and other expenses
          associated with the conduct of the arbitration proceedings shall be borne by the
            [
                                    <i>Contracting States</i>
                                    ] in equal shares.
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 26 (Compatibility) of the MLI</num>
                            <content>
                                <p>
                                    2. Any unresolved issue arising from a mutual agreement procedure case otherwise
          within the scope of the arbitration process provided for in [
                                    <i>Part VI of the
            MLI</i>
                                    ] shall not be submitted to arbitration if the issue falls within the
          scope of a case with respect to which an arbitration panel or similar body has previously
          been set up in accordance with a bilateral or multilateral convention that provides for
          mandatory binding arbitration of unresolved issues arising from a mutual agreement
          procedure case.
                                </p>
                                <p>
                                    3. [
                                    <i>Nothing</i>
                                    ] in [
                                    <i>Part VI of the MLI</i>
                                    ]
          shall affect the fulfilment of wider obligations with respect to the arbitration of
          unresolved issues arising in the context of a mutual agreement procedure resulting from
          other conventions to which the [
                                    <i>Contracting States</i>
                                    ] are or will
          become parties.
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Subparagraph a) of paragraph 2 of Article 28 (Cases eligible to arbitration) of the MLI</num>
                            <content>
                                <p>
                                    <i>Pursuant to subparagraph a) of paragraph 2 of Article 28 of the MLI, the
            Republic of Finland formulates the following reservations with respect to the scope of
            cases that shall be eligible for arbitration under the provisions of Part VI of the
            MLI:</i>
                                </p>
                                <p>
                                    1. Finland reserves the right to exclude from the scope of [
                                    <i>Part VI of
            the MLI</i>
                                    ] cases involving the application of domestic anti-avoidance rules of
          either [
                                    <i>Contracting State</i>
                                    ]. For this purpose, Finland's domestic
          anti-avoidance rules shall include Act on Assessment Procedure (verotusmenettelystä
          annettu laki (1558/1995)) sections 27–30, Act on the Taxation of Business Profits and
          Income from Professional Activities (elinkeinotulon verottamisesta annettu laki
          (360/1968)) section 6 a, subsection 9 and section 52 h and Act on the Taxation of
          Shareholders in Controlled Foreign Companies (ulkomaisten väliyhteisöjen osakkaiden
          verotuksesta annetun laki (1217/1994)). Any subsequent provisions replacing, amending or
          updating these anti-avoidance rules would also be included in this reservation. Finland
          shall notify the Depositary of any such subsequent provisions.
                                </p>
                                <p>
                                    2. Finland reserves the right to exclude from the scope of [
                                    <i>Part VI of
            the MLI</i>
                                    ] cases involving conduct for which the taxpayer or a person acting
          on the taxpayer’s behalf has been found guilty by a court of tax fraud or other tax
          related criminal offence in either [
                                    <i>Contracting State</i>
                                    ]. For this
          purpose, Finland's domestic rules shall include the Criminal Code (rikoslaki (39/1889))
          chapter 29 sections 1-4. Any subsequent provisions replacing, amending or updating these
          rules would also be included in this reservation. Finland shall notify the Depositary of
          any such subsequent provisions.
                                </p>
                                <p>
                                    3. Finland reserves the right to exclude from the scope of [
                                    <i>Part VI of
            the MLI</i>
                                    ] cases concerning items of income [ ] where there is no double
          taxation. Double taxation means that both [
                                    <i>Contracting States</i>
                                    ] have
          imposed taxes in respect of the same taxable income [ ] giving rise to either additional
          tax charge, increase in tax liabilities or cancellation or reduction of losses, which
          could be used to offset taxable profits.
                                </p>
                                <p>
                                    4. Finland reserves the right to exclude from the scope of [
                                    <i>Part VI of
            the MLI</i>
                                    ]:
                                </p>
                                <p>a) with respect to taxes withheld at source on amounts paid or credited to
          non-residents, cases which concern taxable events giving rise to such taxes that occur
          before the reference date;</p>
                                <p>b) with respect to all other taxes, cases which concern taxes levied with respect
          to taxable periods that begin before the reference date.</p>
                                <p>For the purposes of this reservation, “the reference date” is the latest
          of:</p>
                                <p>
                                    i) the date of entry into effect of [
                                    <i>the MLI</i>
                                    ] in both
            [
                                    <i>Contracting States</i>
                                    ] with respect to such taxes;
                                </p>
                                <p>
                                    ii) the first day of January of the calendar year next following the expiration of
          a period of six calendar months beginning on the date of the communication by the
          Depositary of the latest definitive reservation withdrawal or notification which results
          in the application of [
                                    <i>Part VI of the MLI</i>
                                    ] between both
            [
                                    <i>Contracting States</i>
                                    ]; and
                                </p>
                                <p>
                                    iii) where the case is a type of case that would be potentially eligible for
          arbitration as a result of the withdrawal, subsequent to the entry into effect of
            [
                                    <i>Part VI of the MLI</i>
                                    ] as between both [
                                    <i>Contracting
            States</i>
                                    ], of [
                                    <i>Contracting State´s</i>
                                    ] reservation made
          pursuant to Article 28(2) or Article 19(12) [
                                    <i>of the MLI</i>
                                    ], the first
          day of January of the calendar year next following the expiration of a period of six
          calendar months beginning on the date of the communication of the Depositary of the
          withdrawal of the reservation.
                                </p>
                                <p>
                                    5. Finland reserves the right to exclude from the scope of [
                                    <i>Part VI of
            the MLI</i>
                                    ] all cases where an application has been filed under the Convention
          on the Elimination of Double Taxation in Connection with the Adjustment of Profits of
          Associated Enterprises (90/436/EEC) - as amended, or under other instruments agreed by the
          member states of the European Union or under domestic rules which implement such
          instruments.
                                </p>
                                <p>
                                    <i>Pursuant to subparagraph a) of paragraph 2 of Article 28 of the MLI,
            Canada formulates the following reservations with respect to the scope of cases that
            shall be eligible for arbitration under the provisions of Part VI of the
            MLI.</i>
                                </p>
                                <p>
                                    1. Canada reserves the right to limit the scope of issues eligible for arbitration
          under the [
                                    <i>MLI</i>
                                    ] to the following:
                                </p>
                                <p>(a) Issues arising under provisions akin to Article 4 (Resident) of the OECD Model
          Tax Convention, but only insofar as the issue relates to the residence of an
          individual;</p>
                                <p>(b) Issues arising under provisions akin to Article 5 (Permanent Establishment) of
          the OECD Model Tax Convention;</p>
                                <p>(c) Issues arising under provisions akin to Article 7 (Business Profits) of the
          OECD Model Tax Convention;</p>
                                <p>(d) Issues arising under provisions akin to Article 9 (Associated Enterprises) of
          the OECD Model Tax Convention;</p>
                                <p>(e) Issues arising under provisions akin to Article 12 (Royalties) of the OECD
          Model Tax Convention, but only insofar as such a provision might apply in transactions
          involving related persons to which provisions akin to Article 9 of the OECD Model Tax
          Convention might apply; and</p>
                                <p>
                                    (f) Any other provisions subsequently agreed by the [
                                    <i>Contracting
            States</i>
                                    ] through an exchange of diplomatic notes.
                                </p>
                                <p>
                                    2. Canada reserves the right to exclude from the scope of the [
                                    <i>Part VI
            of the MLI</i>
                                    ] issues pertaining to the application of anti-abuse provisions
          whether contained in the [
                                    <i>MLI</i>
                                    ], [
                                    <i>the
            Convention</i>
                                    ], or the domestic law of a [
                                    <i>Contracting
            State</i>
                                    ].
                                </p>
                            </content>
                        </article>
                    </chapter>
                </embeddedStructure>
            </p>
            <article eId="art_24">
                <num>Article 24</num>
                <heading>Exchange of Information</heading>
                <content>
                    <p>1. The competent authorities of the Contracting States shall exchange such information
      as is foreseeably relevant for carrying out the provisions of this Convention or to the
      administration or enforcement of the domestic laws concerning taxes of every kind and
      description imposed on behalf of the Contracting States insofar as the taxation thereunder is
      not contrary to the Convention. In the case of Finland, such exchange of information also
      covers taxes imposed on behalf of its local authorities. The exchange of information is not
      restricted by Articles 1 and 2. </p>
                    <p>2. Any information received under paragraph 1 by a Contracting State shall be treated
      as secret in the same manner as information obtained under the domestic laws of that State and
      shall be disclosed only to persons or authorities (including courts and administrative bodies)
      concerned with the assessment or collection of, the enforcement or prosecution in respect of,
      the determination of appeals in relation to, the taxes referred to in paragraph 1, or the
      oversight of the above. Such persons or authorities shall use the information only for such
      purposes. They may disclose the information in public court proceedings or in judicial
      decisions.</p>
                    <p>3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose
      on a Contracting State the obligation:</p>
                    <p>a) to carry out administrative measures at variance with the laws and administrative
      practice of that or of the other Contracting State;</p>
                    <p>b) to supply information which is not obtainable under the laws or in the normal
      course of the administration of that or of the other Contracting State;</p>
                    <p>c) to supply information which would disclose any trade, business, industrial,
      commercial or professional secret or trade process, or information, the disclosure of which
      would be contrary to public policy.</p>
                    <p>4. If information is requested by a Contracting State in accordance with this Article,
      the other Contracting State shall use its information gathering measures to obtain the
      requested information, even though that other State may not need such information for its own
      tax purposes. The obligation contained in the preceding sentence is subject to the limitations
      of paragraph 3 but in no case shall such limitations be construed to permit a Contracting
      State to decline to supply information solely because it has no domestic interest in such
      information.</p>
                    <p>5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting
      State to decline to supply information solely because the information is held by a bank, other
      financial institution, nominee or person acting in an agency or a fiduciary capacity or
      because it relates to ownership interests in a person.</p>
                </content>
            </article>
            <article eId="art_25">
                <num>Article 25</num>
                <heading>Diplomatic Agents and Consular Officers</heading>
                <content>
                    <p>1. Nothing in this Convention shall affect the fiscal privileges of diplomatic agents
      or consular officers under the general rules of international law or under the provisions of
      special agreements.</p>
                    <p>2. Notwithstanding Article 4, an individual who is a member of a diplomatic mission,
      consular post or permanent mission of a Contracting State which is situated in the other
      Contracting State or in a third State shall be deemed for the purposes of the Convention to be
      a resident of the sending State if that individual is liable in the sending State to the same
      obligations in relation to tax on total income as are residents of that sending
      State.</p>
                    <p>3. The Convention shall not apply to International Organizations, to organs or
      officials thereof and to persons who are members of a diplomatic mission, consular post or
      permanent mission of a third State, being present in a Contracting State and who are not
      liable in either Contracting State to the same obligations in relation to tax on their total
      income as are residents thereof.</p>
                </content>
            </article>
            <p>
                <embeddedStructure class="mli-addition">
                    <p>
                        <authorialNote>
                            <p>
                                The following paragraph 1 of Article 7 of the MLI applies and supersedes the
      provisions of this Convention:
                                <authorialNote marker="4" placement="bottom">
                                    <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
          Article 7 of the MLI has effect with respect to the application of this Convention by the
          Republic of Finland:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2020;
          and</p>
                                    <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2021;</p>
                                    <p>and,</p>
                                    <p>In accordance with paragraph 1 of Article 35 of the MLI, paragraph 1 of Article 7
          of the MLI has effect with respect to the application of the Convention by
          Canada:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2020;
          and</p>
                                    <p>b) with respect to all other taxes levied by Canada, for taxes levied with respect
          to taxable periods beginning on or after 1 June 2020.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision)</num>
                        <content>
                            <p>
                                Notwithstanding any provisions of [
                                <i>the Convention</i>
                                ], a benefit
        under [
                                <i>the Convention</i>
                                ] shall not be granted in respect of an item of
        income [ ] if it is reasonable to conclude, having regard to all relevant facts and
        circumstances, that obtaining that benefit was one of the principal purposes of any
        arrangement or transaction that resulted directly or indirectly in that benefit, unless it
        is established that granting that benefit in these circumstances would be in accordance with
        the object and purpose of the relevant provisions of [
                                <i>the
        Convention</i>
                                ].
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <article eId="art_26">
                <num>Article 26</num>
                <heading>Miscellaneous Rules</heading>
                <content>
                    <p>1. The provisions of this Convention shall not be construed to restrict in any manner
      any exclusion, exemption, deduction, credit or other allowance now or hereafter
      accorded:</p>
                    <p>a) by the laws of a Contracting State in the determination of the tax imposed by that
      State, or</p>
                    <p>b) by any other agreement entered into by a Contracting State.</p>
                    <p>2. Nothing in the Convention shall be construed as preventing a Contracting State from
      imposing a tax on amounts included in the income of a resident of that State with respect to a
      partnership, trust, company or other entity, in which that resident has an
      interest.</p>
                    <p>3. The Convention shall not apply to any company, trust or other entity that is a
      resident of a Contracting State and is beneficially owned or controlled, directly or
      indirectly, by one or more persons who are not residents of that State, if the amount of the
      tax imposed on the income or capital of the company, trust or other entity by that State
      (after taking into account any reduction or offset of the amount of tax in any manner,
      including a refund, reimbursement, contribution, credit or allowance to the company, trust, or
      other entity or to any other person) is substantially lower than the amount that would be
      imposed by that State if all of the shares of the capital stock of the company or all of the
      interests in the trust or other entity, as the case may be, were beneficially owned by one or
      more individuals who were residents of that State.</p>
                    <p>4. Notwithstanding anything in the Convention, alimony and other similar payments
      arising in the Contracting State and paid to a resident of the other Contracting State who is
      subject to tax therein in respect thereof shall be taxable only in that other State but the
      amount taxable in that other State shall not exceed the amount that would be taxable in the
      first-mentioned State if the recipient were a resident thereof.</p>
                    <p>5. The competent authorities of the Contracting States may communicate with each other
      directly for the purpose of applying the Convention.</p>
                    <p>6. For the purposes of paragraph 3 of Article XXII (Consultation) of the General
      Agreement on Trade in Services, the Contracting States agree that, notwithstanding that
      paragraph, any dispute between them as to whether a measure falls within the scope of the
      Convention may be brought before the Council for Trade in Services, as provided by that
      paragraph, only with the consent of both Contracting States. Any doubt as to the
      interpretation of this paragraph shall be resolved under paragraph 4 of Article 23 or, failing
      agreement under that procedure, pursuant to any other procedure agreed to by both Contracting
      States.</p>
                    <p>7. Contributions in a year in respect of services rendered in that year paid by, or on
      behalf of, an individual who is a resident of a Contracting State to a pension plan that is
      recognized for tax purposes in the other Contracting State shall, during a period not
      exceeding in the aggregate 48 months, be treated in the same way for tax purposes in the
      first-mentioned State as a contribution paid to a pension plan that is recognized for tax
      purposes in that first-mentioned State, if</p>
                    <p>a) such individual was contributing on a regular basis to the pension plan for a
      period ending immediately before that individual became a resident of the first-mentioned
      State; and</p>
                    <p>b) the competent authority of the first-mentioned State agrees that the pension plan
      generally corresponds to a pension plan recognized for tax purposes by that State.</p>
                    <p>For the purposes of this paragraph, "pension plan" includes a pension plan created
      under the social security system in a Contracting State.</p>
                </content>
            </article>
            <article eId="art_27">
                <num>Article 27</num>
                <heading>Entry into Force</heading>
                <content>
                    <p>1. The Governments of the Contracting States shall notify each other that the
      constitutional requirements for the entry into force of this Convention have been complied
      with.</p>
                    <p>2. The Convention shall enter into force thirty days after the date of the later of
      the notifications referred to in paragraph 1 and its provisions shall have effect:</p>
                    <p>a) in Canada:</p>
                    <p>(i) in respect of tax withheld at the source on amounts paid or credited to non
      residents, on or after 1 January in the calendar year in which the later of the notifications
      referred to in paragraph 1 takes place; and</p>
                    <p>(ii) in respect of other Canadian tax, for taxation years beginning on or after 1
      January in the calendar year in which the later of the notifications referred to in paragraph
      1 takes place;</p>
                    <p>b) in Finland:</p>
                    <p>(i) in respect of taxes withheld at source, on income derived on or after 1 January in
      the calendar year in which the later of the notifications referred to in paragraph 1 takes
      place; and</p>
                    <p>(ii) in respect of other taxes on income, for taxes chargeable for any taxable year
      beginning on or after 1 January in the calendar year in which the later of the notifications
      referred to in paragraph 1 takes place.</p>
                    <p>3. The provisions of the Convention between Canada and Finland for the Avoidance of
      Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at
      Helsinki on May 28, 1990 (hereinafter referred to as "the 1990 Convention") shall cease to
      have effect with respect to taxes to which this Convention applies in accordance with the
      provisions of paragraph 2.</p>
                    <p>4. The 1990 Convention shall terminate on the last date on which it has effect in
      accordance with the foregoing provisions of this Article.</p>
                </content>
            </article>
            <article eId="art_28">
                <num>Article 28</num>
                <heading>Termination</heading>
                <content>
                    <p>This Convention shall remain in force until terminated by one of the Contracting
      States. Either Contracting State may terminate the Convention, through diplomatic channels, by
      giving notice of termination at least six months before the end of any calendar year following
      after the period of 5 years from the date on which the Convention enters into force. In such
      event, the Convention shall cease to have effect:</p>
                    <p>a) in Canada:</p>
                    <p>(i) in respect of tax withheld at the source on amounts paid or credited to non
      residents, on or after 1 January in the calendar year next following that in which the notice
      is given; and</p>
                    <p>(ii) in respect of other Canadian tax, for taxation years beginning on or after 1
      January in the calendar year next following that in which the notice is given;</p>
                    <p>b) in Finland:</p>
                    <p>(i) in respect of taxes withheld at source, on income derived on or after 1 January in
      the calendar year next following the year in which the notice is given; and</p>
                    <p>(ii) in respect of other taxes on income, for taxes chargeable for any taxable year
      beginning on or after 1 January in the calendar year next following the year in which the
      notice is given.</p>
                </content>
            </article>
            <hcontainer name="conclusions">
                <content>
                    <p>In witness whereof the undersigned, duly authorized to that effect, have signed this
    Convention.</p>
                    <p>Done in duplicate at Helsinki, this day of 20 July 2006, in the Finnish, Swedish,
    English and French languages, each version being equally authentic.</p>
                </content>
            </hcontainer>
        </mainBody>
    </doc>
</akomaNtoso>
