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                <finlex:documentYear>1983</finlex:documentYear>
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                        <finlex:ref href="/akn/fi/act/statute/1983/790"/>
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                        <finlex:ref href="/akn/fi/act/statute/1983/791"/>
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        <preface>
            <p>
                <docNumber>54-55/1983</docNumber>
                <docTitle>Convention between Finland and Italy for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital</docTitle>
            </p>
        </preface>
        <preamble>
            <p class="title">Convention between Finland and Italy for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital</p>
            <p>The Government of Finland and the Government of Italy, </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 and on capital, </p>
            <p>Have agreed as follows:</p>
        </preamble>
        <mainBody>
            <article eId="art_1">
                <num>Article 1</num>
                <heading>Personal scope</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. This Convention shall apply to taxes on income and on capital imposed on behalf of
      a Contracting State or of its political or administrative subdivisions, public communities or
      local authorities, irrespective of the manner in which they are levied.</p>
                    <p>2. There shall be regarded as taxes on income and on capital all taxes imposed on
      total income, on total capital, or on elements of income or of capital, including taxes on
      gains from the alienation of movable or immovable property, as well as taxes on capital
      appreciation.</p>
                    <p>3. The existing taxes to which the Convention shall apply are, in
      particular:</p>
                    <p>a) In Finland:</p>
                    <p>(i) the state income and capital tax (tulo- ja varallisuusvero);</p>
                    <p>(ii) the communal tax (kunnallisvero);</p>
                    <p>(iii) the church tax (kirkollisvero);</p>
                    <p>(iv) the sailors’ tax (merimiesvero); and</p>
                    <p>(v) the tax withheld at source from nonresidents’ income (lähdevero);</p>
                    <p>(hereinafter referred to as “Finnish tax”);</p>
                    <p>h) In Italy:</p>
                    <p>(i) the personal income tax (l'imposta sul reddito delle persone fisiche);</p>
                    <p>(ii) the corporate income tax (l'imposta sul reddito delle persone
      giuridiche);</p>
                    <p>(iii) the local income tax (l'imposta locale sui redditi);</p>
                    <p>even if they are collected by withholding taxes at the source;</p>
                    <p>(hereinafter referred to as “Italian tax”).</p>
                    <p>4. The Convention shall apply also to any identical or substantially similar taxes
      which 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 which have been made in their respective taxation
      laws.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_1" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1983/55#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <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 “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, the
      rights of Finland with respect to the exploration and exploitation of the natural resources of
      the sea bed and its subsoil may be exercised;</p>
                    <p>b) the term "Italy" means the Republic of Italy and includes any area beyond the
      territorial waters of Italy which, in accordance with the laws of Italy concerning the
      exploration and exploitation of natural resources, may be designated as an area within which
      the rights of Italy with respect to the sea bed and subsoil and their natural resources may be
      exercised;</p>
                    <p>c) the terms “a Contracting State” and “the other Contracting State” mean Finland or
      Italy, as the context requires;</p>
                    <p>d) the term "person" includes an individual, a company 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 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>g) the term "national" means</p>
                    <p>(i) any individual possessing the nationality of a Contracting State;</p>
                    <p>(ii) any legal person, partnership and association deriving its status as such from
      the law in force in a Contracting State;</p>
                    <p>h) the term "international traffic" means any transport by a ship or aircraft operated
      by an enterprise which has its place of effective management in a Contracting State, except
      when the ship or aircraft is operated solely between places in the other Contracting
      State;</p>
                    <p>i) the term "competent authority" means:</p>
                    <p>(i) in the case of Finland, the Ministry of Finance or its authorised
      representative;</p>
                    <p>(ii) in the case of Italy, the Ministry of Finance.</p>
                    <p>2. As regards the application of the Convention by a Contracting State any term not
      otherwise defined therein shall, unless the context otherwise requires, have the meaning which
      it has under the law of that State concerning the taxes to which the Convention
      applies.</p>
                </content>
            </article>
            <article eId="art_4">
                <num>Article 4</num>
                <heading>Fiscal domicile</heading>
                <content>
                    <p>1. For the purposes of this Convention, the term "resident of a Contracting State"
      means any person who, under the law of that State, is liable to taxation therein by reason of
      his domicile, residence, place of management or any other criterion of a similar nature.
      However, this term does not include any person who is liable to taxation in that Contracting
      State in respect only of income from sources in that State or capital situated
      therein.</p>
                    <p>2. Where by reason of the provisions of paragraph 1 an individual is a resident of
      both Contracting States, then his status shall be determined as follows:</p>
                    <p>a) He shall be deemed to be a resident of the State in which he has a permanent home
      available to him. If he has a permanent home available to him in both States, he shall be
      deemed to be a resident of the State with which his personal and economic relations are closer
      (centre of vital interests);</p>
                    <p>b) If the State in which he has his centre of vital interests cannot be determined, or
      if he has not a permanent home available to him in either State, he shall be deemed to be a
      resident of the State in which he has an habitual abode;</p>
                    <p>c) If the has an habitual abode in both States or in neither of them, he shall be
      deemed to be a resident of the State of which he is a national;</p>
                    <p>d) If he 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 person other than an individual
      is a resident of both Contracting States, then it shall be deemed to be a resident of the
      State in which its place of effective management is situated.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_2" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1983/55#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <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 the enterprise is wholly or partly
      carried on.</p>
                    <p>2. The term "permanent establishment" shall include 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;</p>
                    <p>f) a mine, a quarry or other place of extraction of natural resources;</p>
                    <p>g) a building site or construction or assembly project which exists for more than
      twelve months.</p>
                    <p>3. 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 for collecting information, for the enterprise;</p>
                    <p>e) the maintenance of a fixed place of business solely for the purpose of advertising,
      for the supply of information, for scientific research or for similar activities which have a
      preparatory or auxiliary character for the enterprise.</p>
                    <p>4. A person acting in a Contracting State on behalf of an enterprise of the other
      Contracting State – other than an agent of an independent status to whom paragraph 5 applies –
      shall be deemed to be a permanent establishment in the first-mentioned State if he has, and
      habitually exercises in that State, an authority to conclude contracts in the name of the
      enterprise, unless his activities are limited to the purchase of goods or merchandise for the
      enterprise.</p>
                    <p>5. 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, where such persons are acting in the ordinary course of their business.</p>
                    <p>6. 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. 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 and 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 shall also be considered as immovable property. Ships, boats 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.</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 owned by the
      company, the income from the direct use, letting, or use in any other form of such right of
      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 and to income from immovable property used for the performance of
      independent personal services.</p>
                    <p>6. The provisions of paragraph 4 shall also apply to the income from a right of
      enjoyment referred to in that paragraph of an enterprise and to income from such right of
      enjoyment used for the performance of independent personal services.</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 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.</p>
                    <p>3. In determining the profits of a permanent establishment, there shall be allowed as
      deductions 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. Insofar as it has been customary in a Contracting State to determine the profits to
      be attributed to a permanent establishment on the basis of an apportionment of the total
      profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that
      Contracting State from determining the profits to be taxed by such an apportionment as may be
      customary. The method of apportionment adopted shall, however, be such that the result shall
      be in accordance with the principles contained in this Article.</p>
                    <p>5. No profits shall be attributed to a permanent establishment by reason of the mere
      purchase by that permanent establishment of goods or merchandise for the
      enterprise.</p>
                    <p>6. 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>7. 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>
            <tblock class="noteEditorial" eId="note_3" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1983/55#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_8">
                <num>Article 8</num>
                <heading>Shipping and air transport</heading>
                <content>
                    <p>1. Profits from the operation of ships or aircraft in international traffic shall be
      taxable only in the Contracting State in which the place of effective management of the
      enterprise is situated.</p>
                    <p>2. If the place of effective management of a shipping enterprise is aboard a ship,
      then it shall be deemed to be situated in the Contracting State in which the home harbour of
      the ship is situated, or, if there is no such home harbour, in the Contracting State of which
      the operator of the ship is a resident.</p>
                    <p>3. The provisions of paragraph 1 shall also apply to profits derived 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>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>
                </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 law of that State, but if the
      recipient is the beneficial owner of the dividends the tax so charged shall not
      exceed:</p>
                    <p>a) 10 per cent of the gross amount of the dividends if the beneficial owner is a
      company (other than a partnership) which holds directly more than 50 per cent of the capital
      of 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 competent authorities of the Contracting States shall by mutual agreement settle
      the mode of application of these limitations.</p>
                    <p>This paragraph shall not affect the taxation of the company in respect of 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 from other
      corporate rights which is subjected 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, or performs in that other State independent personal services
      from a fixed base situated therein, and the holding in respect of which the dividends are paid
      is effectively connected with such permanent establishment or fixed base. In such case the
      dividends are taxable in that other Contracting State according to its own law.</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 or a fixed base situated in that other
      State, nor subject the company's undistributed profits to a tax on the company's 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>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_4" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1983/55#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <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 law of that State, but if the recipient is the beneficial owner
      of the interest, the tax so charged shall not exceed 15 per cent of the gross amount of the
      interest. The competent authorities of the Contracting States shall by mutual agreement settle
      the mode of application of this limitation.</p>
                    <p>3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting
      State shall be exempt from tax in that State if:</p>
                    <p>a) the payer of the interest is the Government of that Contracting State, or a
      political or an administrative subdivision, or a public community, or a local authority
      thereof; or</p>
                    <p>b) the interest is paid to the Government of the other Contracting State, or a
      political or an administrative subdivision, or a public community, or a local authority
      thereof or any agency or instrumentality (including a financial institution) wholly owned by
      that other Contracting State, or political or administrative subdivision, or public community
      or local authority thereof; or</p>
                    <p>c) the interest is paid to any other agency or instrumentality (including a financial
      institution) in relation to loans made in application of an agreement concluded between the
      Governments of the Contracting States.</p>
                    <p>4. The term "interest" as used in this Article means income from Government
      securities, bonds or debentures, whether or not secured by mortage and whether or not carrying
      a right to participate in profits, and debt-claims of every kind as well as all other income
      assimilated to income from money lent by the taxation law of the State in which the income
      arises.</p>
                    <p>5. 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, or performs in that other State independent personal services from a fixed base
      situated therein, and the debt-claim in respect of which the interest is paid is effectively
      connected with such permanent establishment or fixed base. In such case the interest is
      taxable in that other Contracting State according to its own law.</p>
                    <p>6. Interest shall be deemed to arise in a Contracting State when the payer is that
      State itself, a political or an administrative subdivision, a public community, a local
      authority or a resident of that State. Where, however, the person paying the interest, whether
      he is a resident of a Contracting State or not, has in a Contracting State a permanent
      establishment or a fixed base in connection with which the indebtedness on which the interest
      is paid was incurred, and such interest is borne by such permanent establishment or fixed
      base, then such interest shall be deemed to arise in the Contracting State in which the
      permanent establishment or fixed base is situated. </p>
                    <p>7. Where, by reason of a special relationship between the payer and the recipient 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 recipient 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 law 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, royalties of the kind referred to in sub-paragraphs b) and c) of paragraph
      3 may also be taxed in the Contracting State in which they arise and according to the law of
      that State, but if the recipient is the beneficial owner of such royalties the tax so charged
      shall not exceed 5 per cent of the gross amount of the royalties. The competent authorities of
      the Contracting States shall by mutual agreement settle the mode of application of this
      limitation.</p>
                    <p>3. The term "royalties" as used in this Article means payments of any kind received as
      a consideration:</p>
                    <p>a) for the use of, or the right to use, any copyright of literary, artistic or
      scientific work;</p>
                    <p>b) for the use of, or the right to use, cinematograph films, and films or tapes for
      television or radio broadcasting, or any patent, trade mark, design or model, plan, secret
      formula or process, or any industrial, commercial, or scientific equipment;</p>
                    <p>c) for information concerning industrial, commercial or scientific
      experience.</p>
                    <p>4. The provisions of paragraphs 1 and 2 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, or performs in that other State independent personal services from a fixed base
      situated therein, and the right or property in respect of which the royalties are paid is
      effectively connected with such permanent establishment or fixed base. In such case the
      royalties are taxable in that other Contracting State according to its own law.</p>
                    <p>5. Royalties shall be deemed to arise in a Contracting State when the payer is that
      State itself, a political or an administrative subdivision, a public community, a local
      authority or a resident of that State. Where, however, the person paying the royalties,
      whether he is a resident of a Contracting State or not, has in a Contracting State a permanent
      establishment or a fixed base in connection with which the liability to pay the royalties was
      incurred, and such royalties are borne by such permanent establishment or fixed base, then
      such royalties shall be deemed to arise in the State in which the permanent establishment or
      fixed base is situated.</p>
                    <p>6. Where, by reason of a special relationship between the payer and the recipient 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 recipient 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 law 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 referred to in Article 6 and situated in the other Contracting State may be taxed in
      that other State.</p>
                    <p>2. Gains derived by a resident of a Contracting State from the alienation of shares or
      other corporate rights referred to in paragraph 4 of Article 6 may be taxed in the Contracting
      State in which the immovable property owned by the company is situated.</p>
                    <p>3. 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 or of movable property pertaining to a fixed base available to a resident of
      a Contracting State in the other Contracting State for the purpose of performing independent
      personal services, including such gains from the alienation of such a permanent establishment
      (alone or with the whole enterprise) or of such fixed base, may be taxed in that other
      State.</p>
                    <p>4. Gains 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 the Contracting State in which the place of effective management of the enterprise is
      situated.</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>
                </content>
            </article>
            <article eId="art_14">
                <num>Article 14</num>
                <heading>Independent personal services</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State in respect of professional
      services or other activities of an independent character shall be taxable only in that State
      unless he has a fixed base regularly available to him in the other Contracting State for the
      purpose of performing his activities. If he has such a fixed base, the income may be taxed in
      the other State but only so much of it as is attributable to that fixed base.</p>
                    <p>2. The term "professional services" includes especially independent scientific,
      literary, artistic, educational or teaching activities as well as the independent activities
      of physicians, lawyers, engineers, architects, dentists and accountants.</p>
                </content>
            </article>
            <article eId="art_15">
                <num>Article 15</num>
                <heading>Dependent personal services</heading>
                <content>
                    <p>1. Subject to the provisions of Articles 16, 18, 19 and 20, 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 in the fiscal 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 or a fixed base which
      the employer has in the other State.</p>
                    <p>3. Notwithstanding the preceding provisions of this Article, remuneration in respect
      of an employment exercised aboard a ship or aircraft in international traffic, may be taxed in
      the Contracting State in which the place of effective management of the enterprise is
      situated.</p>
                </content>
            </article>
            <article eId="art_16">
                <num>Article 16</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 any other 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_17">
                <num>Article 17</num>
                <heading>Artistes and athletes</heading>
                <content>
                    <p>1. Notwithstanding the provisions of Articles 14 and 15, 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 an athlete, from his 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 an
      athlete in his capacity as such accrues not to the entertainer or athlete himself but to
      another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be
      taxed in the Contracting State in which the activities of the entertainer or athlete are
      exercised.</p>
                </content>
            </article>
            <article eId="art_18">
                <num>Article 18</num>
                <heading>Pensions</heading>
                <content>
                    <p>1. Subject to the provisions of paragraph 2 of this Article or paragraph 2 of Article
      19, pensions and other similar remuneration paid to a resident of a Contracting State in
      consideration of past employment shall be taxable only in that State.</p>
                    <p>2. Subject to the provisions of paragraph 2 of Article 19, pensions and other payments
      made under the social security legislation of a Contracting State may be taxed in that State.
      This provision shall apply only to nationals of that State.</p>
                </content>
            </article>
            <article eId="art_19">
                <num>Article 19</num>
                <heading>Government service</heading>
                <content>
                    <p>1. a) Remuneration, other than a pension, paid by a Contracting State or a political
      or an administrative subdivision, a public community or a local authority thereof to any
      individual in respect of services rendered to that State or subdivision or community or local
      authority thereof shall be taxable only in that State.</p>
                    <p>b) However, such remuneration shall be taxable only in the Contracting State of which
      the individual is a resident if the services are rendered in that State and the
      individual:</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. a) Any pension paid by, or out of funds created by, a Contracting State, a
      political or an administrative subdivision, a public community or a local authority thereof to
      an individual in respect of services rendered to that State or subdivision or community or
      local authority thereof shall be taxable only in that State.</p>
                    <p>b) However, such pension shall be taxable only in the Contracting State of which the
      individual is a resident if he is a national of that State.</p>
                    <p>3. The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions
      in respect of services rendered in connection with a business carried on by a Contracting
      State, or a political or an administrative subdivision, a public community or a local
      authority thereof.</p>
                </content>
            </article>
            <article eId="art_20">
                <num>Article 20</num>
                <heading>Students</heading>
                <content>
                    <p>Payments which a student or business, technical, agricultural or forestry apprentice
      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
      his education or training receives for the purpose of his 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_21">
                <num>Article 21</num>
                <heading>Other income</heading>
                <content>
                    <p>1. Items of income of a resident of a Contracting State, wherever arising, not dealt
      with in the foregoing Articles of this Convention shall be taxable only in that
      State.</p>
                    <p>2. The provisions of paragraph 1 shall not apply to income, other than income from
      immovable property as defined in paragraph 2 of Article 6, if the recipient of such income,
      being a resident of a Contracting State, carries on business in the other Contracting State
      through a permanent establishment situated therein, or performs in that other State
      independent personal services from a fixed base situated therein, and the right or property in
      respect of which the income is paid is effectively connected with such permanent establishment
      or fixed base. In such case the items of income are taxable in that other Contracting State
      according to its own law.</p>
                </content>
            </article>
            <article eId="art_22">
                <num>Article 22</num>
                <heading>Capital</heading>
                <content>
                    <p>1. Capital represented by immovable property referred to in paragraph 2 of Article 6,
      owned by a resident of a Contracting State and situated in the other Contracting State, may be
      taxed in that other State.</p>
                    <p>2. Capital represented by shares or other corporate rights referred to in paragraph 4
      of Article 6 may be taxed in the Contracting State in which the immovable property owned by
      the company is situated.</p>
                    <p>3. Capital represented by 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 or by movable property pertaining to a fixed base available to a resident of
      a Contracting State in the other Contracting State for the purpose of performing independent
      personal services, may be taxed in that other State.</p>
                    <p>4. Capital represented by ships and aircraft operated in international traffic, and
      movable property pertaining to the operation of such ships and aircraft, shall be taxable only
      in the Contracting State in which the place of effective management of the enterprise is
      situated.</p>
                    <p>5. All other elements of capital of a resident of a Contracting State shall be taxable
      only in that State.</p>
                </content>
            </article>
            <article eId="art_23">
                <num>Article 23</num>
                <heading>Elimination of double taxation</heading>
                <content>
                    <p>1. In the case of Italy, double taxation shall be eliminated as follows: </p>
                    <p>If a resident of Italy owns items of income which are taxable in Finland, Italy, in
      determining its income taxes specified in Article 2 of this Convention, may include in the
      basis upon which such taxes are imposed the said items of income, unless specific provisions
      of this Convention otherwise provide. </p>
                    <p>In such a case, Italy shall deduct from the taxes so calculated the Finnish tax paid
      on income, but in an amount not exceeding that proportion of the aforesaid Italian tax which
      such items of income bear to the entire income.</p>
                    <p>However, no deduction will be granted if the item of income is subjected in Italy to a
      final withholding tax by request of the recipient of the said income in accordance with
      Italian law.</p>
                    <p>2. In the case of Finland, double taxation shall be eliminated as follows:</p>
                    <p>a) Where a resident of Finland derives income or owns capital which, in accordance
      with the provisions of this Convention, may be taxed in Italy, Finland shall, where the
      provisions of sub-paragraph b) are not applicable, allow:</p>
                    <p>(i) as a deduction from the tax on the income of that resident, an amount equal to the
      income tax paid in Italy,</p>
                    <p>(ii) as a deduction from the tax on the capital of that resident, an amount equal to
      the capital tax paid in Italy.</p>
                    <p>Such deduction in either case shall not, however, exceed that part of the income tax
      or capital tax, as computed before the deduction is given, which is attributable, as the case
      may be, to the income or the capital which may be taxed in Italy.</p>
                    <p>b) Notwithstanding the provisions of subparagraph a), dividends paid by a company
      which is a resident of Italy to a company which is a resident of Finland shall be exempt from
      Finnish tax to the extent that the dividends would have been exempt from tax under Finnish
      taxation law if both companies had been residents of Finland.</p>
                    <p>3. Where a resident of a Contracting State receives any payment referred to in
      paragraph 2 of Article 18 which may be taxed in the other Contracting State, that other State
      shall allow as a deduction from the tax on income of that resident an amount equal to the tax
      on income paid in the first mentioned State. Such deduction, however, shall not exceed that
      part of the income tax, as computed before the deduction is given, which is attributable to
      the payments which may be taxed in that other State.</p>
                    <p>4. Where, in accordance with the laws of a Contracting State, taxes covered by this
      Convention are exempted or reduced for the purpose of encouraging economic development in that
      State for a limited period of time, that part of such taxes which has been exempted or reduced
      shall be deemed to have been paid for the purpose of the preceding paragraphs of this
      Article.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_5" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1983/55#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_24">
                <num>Article 24</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 other or more
      burdensome than the taxation and connected requirements to which nationals of that other State
      in the same circumstances are or may be subjected. This provision shall, notwithstanding the
      provisions of Article 1, also apply to persons who are not residents of one or both of the
      Contracting States.</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. This provision shall not be construed as obliging a Contracting State to grant to
      residents of the other Contracting State any 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>3. Except where the provisions of Article 9, paragraph 7 of Article 11, or paragraph 6
      of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a
      Contracting State to a resident of the other Contracting State shall, for the purpose of
      determining the taxable profits of such enterprise, be deductible under the same conditions as
      if they had been paid to a resident of the first-mentioned State. Similarly, any debts of an
      enterprise of a Contracting State to a resident of the other Contracting State shall, for the
      purpose of determining the taxable capital of such enterprise, be deductible under the same
      conditions as if they had been contracted to a resident of the first-mentioned
      State.</p>
                    <p>4. Enterprises of a Contracting State, the capital of which is wholly or partly owned
      or controlled, directly or indirectly, by one or more residents of the other Contracting
      State, shall not be subjected in the first-mentioned State to any taxation or any requirement
      connected therewith which is other or more burdensome than the taxation and connected
      requirements to which other similar enterprises of the first-mentioned State are or may be
      subjected.</p>
                    <p>5. The provisions of this Article shall, notwithstanding the provisions of Article 2,
      apply to taxes of every kind and description.</p>
                </content>
            </article>
            <article eId="art_25">
                <num>Article 25</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 him in taxation not in accordance with the provisions of this
      Convention, he may, irrespective of the remedies provided by the domestic law of those States,
      present his case to the competent authority of the Contracting State of which he is a resident
      or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of
      which he is a national. The case must be presented within two years from the first
      notification of the action resulting in taxation not in accordance with the provisions of the
      Convention.</p>
                    <p>2. The competent authority 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. 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.</p>
                    <p>4. The competent authorities of the Contracting States may communicate with each other
      directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.
      When it seems advisable in order to reach agreement to have an oral exchange of opinions, such
      exchange may take place through a Commission consisting of representatives of the competent
      authorities of the Contracting States.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_6" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1983/55#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_26">
                <num>Article 26</num>
                <heading>Exchange of information</heading>
                <content>
                    <p>1. The competent authorities of the Contracting States shall exchange such information
      as is necessary for carrying out the provisions of this Convention or of the domestic laws of
      the Contracting States as well as preventing fiscal evasion concerning taxes covered by the
      Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange
      of information is not restricted by Article 1. Any information received 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) involved in the assessment or collection of, the enforcement or
      prosecution in respect of, or the determination of appeals in relation to, the taxes covered
      by the Convention. 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>2. ln no case shall the provisions of paragraph 1 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 the
      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 (ordre public).</p>
                </content>
            </article>
            <article eId="art_27">
                <num>Article 27</num>
                <heading>Diplomatic agents and consular officers</heading>
                <content>
                    <p>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>
                </content>
            </article>
            <article eId="art_28">
                <num>Article 28</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 respect of taxes withheld at source, to income arising on or after 1 January in
      the calendar year next following the year in which the Convention enters into force; </p>
                    <p>b) in respect of other taxes on income, and taxes on capital, to taxes chargeable for
      any taxable period beginning on or after 1 January in the calendar year next following the
      year in which the Convention enters into force.</p>
                    <p>3. The Convention between Finland and Italy for the avoidance of double taxation and
      the prevention of fiscal evasion with respect to taxes on income and on capital signed at Rome
      on 4 August 1967, as amended by the exchange of notes dated 7 May 1971 and 19 June 1971, shall
      terminate. Its provisions shall cease to have effect from the date on which the provisions of
      the present Convention according to the provisions of paragraph 2 apply for the first
      time.</p>
                </content>
            </article>
            <article eId="art_29">
                <num>Article 29</num>
                <heading>Termination</heading>
                <content>
                    <p>This Convention shall remain in force until terminated by a Contracting State. 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 five 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 respect of taxes withheld at source, to income arising on or after 1 January in
      the calendar year next following the year in which the notice is given;</p>
                    <p>b) in respect of other taxes on income, and taxes on capital, to taxes chargeable for
      any taxable period beginning on or after 1 January in the calendar year next following the
      year in which the notice is given. </p>
                    <p>In witness whereof the undersigned, duly authorised thereto, have signed this
      Convention.</p>
                    <p>Done in duplicate at Helsinki this 12th day of June 1981, in the Finnish, Italian and
      English languages, all three texts being equally authoritative. In case of any divergence of
      interpretation the English text shall prevail.</p>
                </content>
            </article>
            <hcontainer name="attachments">
                <hcontainer eId="protocol" name="attachment">
                    <heading>Protocol</heading>
                    <content>
                        <p>At the signing today of the Convention between Finland and Italy for the avoidance of
      double taxation and the prevention of fiscal evasion with respect to taxes on income and on
      capital, the undersigned have agreed upon the following provisions which shall form an
      integral part of the Convention:</p>
                        <tblock>
                            <num>1. Ad Article 2, paragraph 3.</num>
                            <p>a) The Convention shall not apply, in the case of Finland, to the national pension
        premium, the sickness insurance premium and the special lottery tax, and, in the case of
        Italy, to taxes (even if they are collected by withholding taxes at source) payable on
        lottery winnings, on prizes other than those connected with securities, and winnings from
        games of chance or ability, contests, guessing games, and betting.</p>
                            <p>b) Where a tax on capital is after the date of signature of the Convention
        introduced in Italy the Convention shall also apply to such tax.</p>
                        </tblock>
                        <tblock>
                            <num>2. Ad Article 4.</num>
                            <p>An undivided estate of a deceased person shall, for the purposes of taxation in
        Finland, be deemed to be a resident of the Contracting State of which the deceased was a
        resident at the time of his death according to the provisions of paragraphs 1 and 2 of the
        Article.</p>
                        </tblock>
                        <tblock>
                            <num>3. Ad Article 7, paragraph 3.</num>
                            <p>The expression "expenses which are incurred for the purposes of the permanent
        establishment" means the expenses directly connected with the activity of the permanent
        establishment.</p>
                        </tblock>
                        <tblock>
                            <num>4. Ad Article 10, paragraph 3.</num>
                            <p>The term "dividends" includes income from "jouissance" shares or "jouissance"
        rights, mining shares and founders' shares.</p>
                        </tblock>
                        <tblock>
                            <num>5. Ad Article 23.</num>
                            <p>a) The Finnish tax on capital levied in accordance with the Convention shall be set
        off against a tax on capital introduced in Italy after the date of signature of the
        Convention in the manner provided for in paragraph 1 of the Article.</p>
                            <p>b) (i) Where a person, being a national of Finland and not a national of Italy, is a
        resident of Italy and under the so called three years rule contained in section 9 of the
        Finnish Act on Income and Capital Tax with respect to the Finnish taxes referred to in
        Article 2 of the Convention is regarded as resident in Finland, Finland may in cases, where
        the provisions of the Convention would restrict the right of Finland to tax, impose its
        taxes on the income of or on capital owned by such person derived from sources or situated,
        as the case may be, outside Italy. However, Finland shall allow any Italian tax paid on the
        income or capital as a deduction from Finnish tax in accordance with the provisions of
        paragraph 2 of the Article.</p>
                            <p>(ii) Where a person, being a national of Italy and not a national of Finland, is a
        resident of Finland and has the principal seat of his affairs and interests in Italy, Italy
        may in cases, where the provisions of the Convention would restrict the right of Italy to
        tax, impose its taxes on income of such person derived from sources outside Finland.
        However, Italy shall allow any Finnish tax paid on income as a deduction from Italian tax in
        accordance with the provisions of paragraph 1 of the Article.</p>
                            <p>(iii) The provisions of sub-paragraphs (i) and (ii) shall apply only for the year
        during which the person left, as the case may be, Finland or Italy and for the subsequent
        three years.</p>
                        </tblock>
                        <tblock>
                            <num>6. Ad Article 25.</num>
                            <p>a) The expression "irrespective of the remedies provided by the domestic law" in
        paragraph 1 of the Article means that the mutual agreement procedure is not alternative with
        the national contentious proceedings which shall be, in any case, preventively initiated,
        when the claim is related to an assessment of taxes not in accordance with the
        Convention.</p>
                            <p>b) Taxes withheld at source in a Contracting State shall be reduced or refunded by
        request of the taxpayer if the right to collect such taxes is affected by the provisions of
        the Convention. Claims for reduction or refund shall be made within the time limits fixed by
        the law of the Contracting State which has to grant the reduction or refund. The claim shall
        be accompanied by necessary documentation concerning the existence of the conditions
        required by the Convention for reduction or refund. The competent authorities of the
        Contracting States shall by mutual agreement settle the mode of application of the foregoing
        provision.</p>
                            <p>In witness whereof the undersigned, duly authorised thereto, have signed this
        Protocol.</p>
                            <p>Done in duplicate at Helsinki this 12th day of June 1981, in the Finnish, Italian
        and English languages, all texts being equally authoritative. In case of any divergence of
        interpretation the English text shall prevail.</p>
                        </tblock>
                    </content>
                </hcontainer>
            </hcontainer>
        </mainBody>
    </doc>
</akomaNtoso>
