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        <preface>
            <p>
                <docNumber>57-58/1981</docNumber>
                <docTitle>Convention between the Republic of Finland and the Hellenic Republic for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital</docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE REPUBLIC OF FINLAND AND THE HELLENIC REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL</heading>
                        <p>This document presents the synthesised text for the application of the Convention
      between the Republic of Finland and the Hellenic Republic for the Avoidance of Double Taxation
      with respect to Taxes on Income and on Capital signed on 21 January 1980 (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 the Hellenic Republic
      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 Agreement by the MLI.</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 the
      Hellenic Republic submitted to the Depositary upon ratification on 30 March 2021. 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 Republic of Finland
      modified its MLI position by withdrawing its reservation made to Article 9 and by making
      additional notifications (consolidated MLI position of the Republic of Finland on 27 June
      2023). These modifications did not modify the effects of the MLI on the Convention.</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 the Hellenic
      Republic 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 30 March 2021 for the Hellenic
      Republic.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 July 2021
      for the Hellenic Republic.</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 the Hellenic Republic
      submitted to the Depositary upon ratification on 30 March 2021 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 the
      Hellenic Republic is published in the Treaty Series of the Statute Book of Finland SopS
      36/2021. Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2021/20210036">https://finlex.fi/fi/sopimukset/sopsteksti/2021/20210036</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2021/fds20210036.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2021/fds20210036.pdf</a>
                        </p>
                        <p>
                            Convention between the Republic of Finland and the Hellenic Republic for the Avoidance
      of Double Taxation with Respect to Taxes on Income and on Capital signed on 21 January 1980 is
      published in the Treaty Series of the Statute Book of Finland SopS 58/1981. Link to Finnish
      language version
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1981/19810058/19810058_2">https://www.finlex.fi/fi/sopimukset/sopsteksti/1981/19810058/19810058_2</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Convention between the Republic of Finland and the Hellenic Republic for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital</p>
            <p>The Government of the Republic of Finland and the Government of the Hellenic
    Republic,</p>
            <p>
                <embeddedStructure class="mli-replaced">
                    <p>
                        <authorialNote>
                            <p>[REPLACED by paragraph 1 of Article 6 of the MLI]</p>
                        </authorialNote>
                    </p>
                    <p>[Desiring to conclude a Convention for the avoidance of double taxation with respect to
      taxes on income and on capital,]</p>
                </embeddedStructure>
            </p>
            <p>
                <embeddedStructure class="mli-replacement">
                    <p>
                        <authorialNote>
                            <p>
                                The following paragraph 1 of Article 6 of the MLI replaces the text referring to
      an intent to eliminate double taxation 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 2022;
          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 2022;</p>
                                    <p>and,</p>
                                    <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 the Convention by the
          Hellenic Republic:</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 2022;
          and</p>
                                    <p>b) with respect to all other taxes levied by the Hellenic Republic, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2022.</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>
            <chapter eId="chp_1">
                <num>Chapter I</num>
                <heading>Scope of the convention</heading>
                <article eId="chp_1__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="chp_1__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 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 :</p>
                        <p>a) in Finland:</p>
                        <p>(i) the state income and capital tax;</p>
                        <p>(ii) the communal tax;</p>
                        <p>(iii) the church tax;</p>
                        <p>(iv) the sailors' tax; and</p>
                        <p>(v) the tax withheld at source from non-residents' income;</p>
                        <p>(hereinafter referred to as "Finnish tax");</p>
                        <p>b) in Greece:</p>
                        <p>(i) the income and capital tax on natural persons;</p>
                        <p>(ii) the income and capital tax on legal persons;</p>
                        <p>(iii) the contribution for the Agricultural Insurance Organisation calculated on
        income tax; and</p>
                        <p>(iv) all other taxes on income, on capital, additional taxes or other contributions
        on income and on capital;</p>
                        <p>(hereinafter referred to as "Greek 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 significant changes which have been made in their respective taxation
        laws.</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_2">
                <num>Chapter II</num>
                <heading>Definitions</heading>
                <article eId="chp_2__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, an 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 sea bed and its sub-soil may be
        exercised;</p>
                        <p>b) the term "Greece" means the Hellenic Republic and, when used in a geographical
        sense, means the territory of the Hellenic Republic, and any area adjacent to the
        territorial waters of the Hellenic Republic within which, under the laws of Greece and in
        accordance with international law, the rights of Greece with respect to the exploration and
        exploitation of the natural resources of the sea bed and its sub-soil may be
        exercised;</p>
                        <p>c) the term "person" includes an individual, a company and any other body of
        persons;</p>
                        <p>d) the term "company" means any body corporate or any entity which is treated as a
        body corporate for tax purposes;</p>
                        <p>e) 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>f) the term "public corporate body" means:</p>
                        <p>(i) in Finland,</p>
                        <p>- municipality</p>
                        <p>- union of municipalities</p>
                        <p>- the Evangelical-Lutheran Church and its local congregations</p>
                        <p>- the Orthodox Church and its local congregations</p>
                        <p>- the Social Insurance Institution</p>
                        <p>- the Bank of Finland</p>
                        <p>- Finnish universities and other corresponding institutions for higher
        education;</p>
                        <p>(ii) in Greece,</p>
                        <p>- municipality and commune</p>
                        <p>- union of municipalities and communes</p>
                        <p>- the Social Insurance Institution</p>
                        <p>- the Bank of Greece</p>
                        <p>- Greek universities and other corresponding institutions for higher
        education;</p>
                        <p>g) the term "nationals" means:</p>
                        <p>(i) all individuals possessing the nationality of a Contracting State;</p>
                        <p>(ii) all legal persons, partnerships and associations deriving their status as such
        from the law in force in a Contracting State;</p>
                        <p>h) the term "international traffic" means any transport by an aircraft operated by
        an enterprise which has its place of effective management in a Contracting State or by a
        ship which has its place of registration in, or it has been documented by, 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 Finland, the Ministry of Finance or its authorised representative;</p>
                        <p>(ii) in Greece, the Ministry of Finance.</p>
                        <p>2. As regards the application of the Convention by a Contracting State any term not
        defined therein shall, unless the context otherwise requires, have the meaning which it has
        under the laws of that State concerning the taxes to which the Convention
        applies.</p>
                    </content>
                </article>
                <article eId="chp_2__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 laws of that State, is liable to tax therein by reason of
        his domicile, residence, place of management or any other criterion of a similar nature. An
        undivided estate of a deceased person shall, for the purposes of taxation, 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 preceding sentence or the provisions of paragraph 2. However, this
        term does not include any person who is liable to tax in that 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 Sates, 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 he 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>
                <article eId="chp_2__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 of extraction of natural
        resources.</p>
                        <p>3. A building site or construction or installation project constitutes a permanent
        establishment only if it lasts more than six 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 sub-paragraphs 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 person 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 shall not be deemed to have a permanent establishment in a
        Contracting State merely because it carries on business in that 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 as 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>
            </chapter>
            <chapter eId="chp_3">
                <num>Chapter III</num>
                <heading>Taxation of income</heading>
                <article eId="chp_3__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. a) The term "immovable property" shall, subject to the provisions of
        sub-paragraphs b) and c), have the meaning which it has under the law of the Contracting
        State in which the property in question is situated.</p>
                        <p>b) The term "immovable property" 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.</p>
                        <p>c) 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 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 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="chp_3__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>
                <article eId="chp_3__art_8">
                    <num>Article 8</num>
                    <heading>Shipping and air transport</heading>
                    <content>
                        <p>1. Profits from the operation of 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. Profits from the operation of ships engaged in international traffic shall be
        taxable only in the Contracting State in which the ships are registered or by which they are
        documented.</p>
                        <p>3. The provisions of paragraph 1 shall also apply to profits from the participation
        in a pool, a joint business or in an international operating agency.</p>
                    </content>
                </article>
                <article eId="chp_3__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>
                <level>
                    <content>
                        <p>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following paragraph 1 of Article 17 of the MLI applies and supersedes the
        provisions of this Convention:
                                            <authorialNote marker="2" placement="bottom">
                                                <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
            Article 17 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
            2022; 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 2022;</p>
                                                <p>and,</p>
                                                <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
            Article 17 of the MLI has effect with respect to the application of the Convention by
            the Hellenic Republic:</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
            2022; and</p>
                                                <p>b) with respect to all other taxes levied by the Hellenic Republic, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2022.</p>
                                            </authorialNote>
                                        </p>
                                    </authorialNote>
                                </p>
                                <article>
                                    <num>ARTICLE 17 OF THE MLI – CORRESPONDING ADJUSTMENTS</num>
                                    <content>
                                        <p>
                                            Where a [
                                            <i>Contracting State</i>
                                            ] includes in the profits of an
          enterprise of that [
                                            <i>Contracting State</i>
                                            ] – and taxes accordingly –
          profits on which an enterprise of the other [
                                            <i>Contracting State</i>
                                            ] has
          been charged to tax in that other [
                                            <i>Contracting State</i>
                                            ] and the
          profits so included are profits which would have accrued to the enterprise of the
          first-mentioned [
                                            <i>Contracting State</i>
                                            ] if the conditions made between
          the two enterprises had been those which would have been made between independent
          enterprises, then that other [
                                            <i>Contracting State</i>
                                            ] shall make an
          appropriate adjustment to the amount of the tax charged therein on those profits. In
          determining such adjustment, due regard shall be had to the other provisions of
            [
                                            <i>the Convention</i>
                                            ] and the competent authorities of the
            [
                                            <i>Contracting States</i>
                                            ] shall if necessary consult each
          other.
                                        </p>
                                    </content>
                                </article>
                            </embeddedStructure>
                        </p>
                    </content>
                </level>
                <article eId="chp_3__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 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 the
        tax so charged shall not exceed:</p>
                        <p>a) 47 per cent of the gross amount of the dividends if the company making the
        distribution is a resident of Greece; and</p>
                        <p>b) 13 per cent of the gross amount of the dividends if the company making the
        distribution is a resident of Finland.</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, "jouissance"
        shares or "jouissance" rights, mining shares, founders' 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 recipient 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 provisions of Article 7 or Article 14, as the case may be, 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 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>
                <article eId="chp_3__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 the tax so charged shall not exceed 10
        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. 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. Penalty charges for late payment shall not be regarded as
        interest for the purpose of this Article.</p>
                        <p>4. The provisions of paragraphs 1 and 2 shall not apply if the recipient 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 provisions of
        Article 7 or Article 14, as the case may be, shall apply.</p>
                        <p>5. Interest shall be deemed to arise in a Contracting State when the payer is that
        State itself, 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>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 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 laws of each Contracting State, due regard being had
        to the other provisions of this Convention.</p>
                    </content>
                </article>
                <article eId="chp_3__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 be taxed in the Contracting State in which they arise and according to the
        laws of that State, but the tax so charged shall not exceed 10 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 including cinematograph films, and films or tapes for televisions or radio
        broadcasting;</p>
                        <p>b) for the use of, or the right to use, 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 recipient of the
        royalties, being a resident of a Contracting State, carries on business in the 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 provisions of
        Article 7 or Article 14, as the case may be, shall apply.</p>
                        <p>5. Royalties shall be deemed to arise in a Contracting State when the payer is that
        State itself, 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 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 laws of each Contracting
        State, due regard being had to the other provisions of this Convention.</p>
                    </content>
                </article>
                <article eId="chp_3__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 paragraph 2 of 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 held 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 profits of such ships or aircraft are taxable
        according to the provisions of Article 8 of this Convention.</p>
                        <p>5. Gains from the alienation of any property other than that referred to in the
        preceding paragraphs of this Article, shall be taxable only in the Contracting State of
        which the alienator is a resident.</p>
                    </content>
                </article>
                <article eId="chp_3__art_14">
                    <num>Article 14</num>
                    <heading>Independent personal service</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="chp_3__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 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 or a fixed base 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, may be taxed in the Contracting State in which the profits from the operation of
        the ship or aircraft are taxable according to the provisions of Article 8 of this
        Convention.</p>
                    </content>
                </article>
                <article eId="chp_3__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="chp_3__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 artist, 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="chp_3__art_18">
                    <num>Article 18</num>
                    <heading>Pensions</heading>
                    <content>
                        <p>1. Subject to the provisions of 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. Notwithstanding the provisions of paragraph 1 and subject to the provisions of
        paragraph 2 of Article 19, pensions and other payments made under the social security
        legislation of a Contracting State shall be taxable only in that State.</p>
                    </content>
                </article>
                <article eId="chp_3__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 public
        corporate body or a local authority thereof to an individual in respect of services rendered
        to that State or body or authority 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 or a
        public corporate body or a local authority thereof to an individual in respect of services
        rendered to that State or body or authority 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 public corporate body or a local authority thereof.</p>
                    </content>
                </article>
                <article eId="chp_3__art_20">
                    <num>Article 20</num>
                    <heading>Students</heading>
                    <content>
                        <p>1. 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>
                        <p>2. A student at a university or other institution for higher education in a
        Contracting State, or a business, technical, agricultural or forestry apprentice who is or
        was immediately before visiting the other Contracting State a resident of the
        first-mentioned State and who is present in the other Contracting State for a period or
        periods not exceeding in the aggregate 183 days in the calendar year concerned, shall not be
        taxed in that other State in respect of remuneration for services rendered in that State,
        provided that the services are in connection with his studies or training and the
        remuneration constitutes earnings necessary for his maintenance.</p>
                    </content>
                </article>
                <article eId="chp_3__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 provisions of Article 7 or Article 14, as the
        case may be, shall apply.</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_4">
                <num>Chapter IV</num>
                <heading>Taxation of capital</heading>
                <article eId="chp_4__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 and owned by a resident of a Contracting State may be taxed in the
        Contracting State in which the immovable property held 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
        Contacting 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 or aircraft in international traffic and movable
        property pertaining to the operation of such ships or aircraft shall be taxable only in the
        Contracting State in which the profits from the aforesaid ships or aircraft are taxable
        according to the provisions of Article 8 of this Convention.</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>
            </chapter>
            <chapter eId="chp_5">
                <num>Chapter V</num>
                <heading>Methods for elimination of double taxation</heading>
                <article eId="chp_5__art_23">
                    <num>Article 23</num>
                    <heading>Credit method</heading>
                    <content>
                        <p>1. In 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 Greece, Finland shall, subject to
        the provisions of sub-paragraph b), allow:</p>
                        <p>i) as a deduction from the tax on income of that resident, an amount equal to the
        tax on income paid in Greece,</p>
                        <p>ii) as a deduction from the tax on capital of that resident, an amount equal to the
        tax on capital paid in Greece.</p>
                        <p>Such deduction in either case shall not, however, exceed that part of the tax on
        income or on capital, 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 Greece.</p>
                        <p>b) Dividends paid by a company which is a resident of Greece 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>c) Where in accordance with any provision of the Convention income derived or
        capital owned by a resident of Finland is exempt from tax in Finland, Finland may,
        nevertheless, in calculating the amount of tax on the remaining income or capital of such
        resident, take into account the exempted income or capital;</p>
                        <p>d) In the application of paragraph 1 of this Article, where Greek tax has been
        relieved or reduced pursuant to Greek legislation which the competent authorities of the
        Contracting States agree to be for the purpose of economic development, the credit against
        Finnish tax shall be allowed in an amount as provided in paragraph 1 a) of this Article
        during a period not exceeding 10 years from the later of</p>
                        <p>i) the date when this Convention has first become effective; or</p>
                        <p>ii) the date when the relief from or reduction in Greek tax has first become
        effective.</p>
                        <p>The competent authorities shall consult each other in order to determine whether
        this period of time shall be extended.</p>
                        <p>2. In Greece double taxation shall be eliminated as follows:</p>
                        <p>Where a resident of Greece derives income or owns capital which, in accordance with
        the provisions of this Convention, may be taxed in Finland, Greece shall allow:</p>
                        <p>i) as a deduction from the tax on income of that resident, an amount equal to the
        tax on income paid in Finland,</p>
                        <p>ii) as a deduction from the tax on capital of that resident, an amount equal to the
        tax on capital paid in Finland.</p>
                        <p>Such deduction in either case shall not, however, exceed that part of the tax on
        income or on capital, 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 Finland.</p>
                        <p>3. Notwithstanding any other provision of this Convention, a national of a
        Contracting State, who claims to have left that State in order to take up his residence in
        the other Contracting State, may still be deemed to be a resident of the first-mentioned
        State until two calendar years have lapsed since the end of the year of his removal unless
        he can prove that he during the taxation year concerned had not essential ties with the
        first-mentioned State. However, the first-mentioned State shall allow any tax of the other
        Contracting State paid on the income or the capital as a deduction from its tax in
        accordance with the provisions of paragraph 1 or 2, as the case may be.</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_6">
                <num>Chapter VI</num>
                <heading>Special provisions</heading>
                <article eId="chp_6__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. Stateless persons who are residents of a Contracting State shall not be subjected
        in either 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
        the State concerned in the same circumstances are or may be subjected.</p>
                        <p>3. 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>4. Except where the provisions of Article 9, paragraph 4 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>5. 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>6. 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="chp_6__art_25">
                    <num>Article 25</num>
                    <heading>Mutual agreement procedure</heading>
                    <content>
                        <p>
                            <embeddedStructure class="mli-replaced">
                                <p>
                                    <authorialNote>
                                        <p>1. [REPLACED by the first sentence of paragraph 1 of Article 16 of the
          MLI]</p>
                                    </authorialNote>
                                </p>
                                <p>[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 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.</p>
                            </embeddedStructure>
                        </p>
                        <p>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following first sentence of paragraph 1 of Article 16 of the MLI replaces
          the first sentence of paragraph 1 of Article 25 of this Convention:
                                            <authorialNote marker="3" placement="bottom">
                                                <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, the first
              sentence of paragraph 1 of Article 16 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
              2022; 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
              2022;</p>
                                                <p>and,</p>
                                                <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, the first
              sentence of paragraph 1 of Article 16 of the MLI has effect with respect to the
              application of the Convention by the Hellenic Republic:</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
              2022; and</p>
                                                <p>b) with respect to all other taxes levied by the Hellenic Republic, for taxes
              levied with respect to taxable periods beginning on or after 1 January
              2022.</p>
                                            </authorialNote>
                                        </p>
                                    </authorialNote>
                                </p>
                                <article>
                                    <num>ARTICLE 16 OF THE MLI – MUTUAL AGREEMENT PROCEDURE</num>
                                    <content>
                                        <p>
                                            Where a person considers that the actions of one or both of the
              [
                                            <i>Contracting States</i>
                                            ] result or will result for that person in
            taxation not in accordance with the provisions of [
                                            <i>this
              Convention</i>
                                            ], that person may, irrespective of the remedies provided by the
            domestic law of those [
                                            <i>Contracting States</i>
                                            ], present the case to
            the competent authority of either [
                                            <i>Contracting State</i>
                                            ].
                                        </p>
                                    </content>
                                </article>
                            </embeddedStructure>
                        </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. Any
        agreement reached shall be implemented notwithstanding any time limits in the domestic law
        of the Contracting States.</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. They may also consult together for the elimination of double taxation in
        cases not provided for in the Convention. In particular, the competent authorities of the
        Contracting States may consult together to endeavour to agree to the same allocation of
        income between a resident of one of the Contracting States and any associated enterprise
        referred to in Article 9.</p>
                        <p>4. In the event the competent authorities reach such an agreement, taxes shall be
        imposed on such income, and refund or credit of taxes shall be allowed by the Contracting
        States in accordance with such agreement.</p>
                        <p>5. 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>
                <level>
                    <content>
                        <p>
                            <embeddedStructure class="mli-addition">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following Part VI of the MLI applies to this Convention:
                                            <authorialNote marker="4" 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 with respect to
            cases presented to the competent authority of a Contracting State on or after 1 July
            2021.</p>
                                                <p>In accordance with paragraph 2 of Article 36 of the MLI, the provisions of Part
            VI (Arbitration) of the MLI apply to a case presented to the competent authority of a
            Contracting State prior to 1 July 2021 only to the extent that the competent authorities
            of both Contracting States agree that it will apply to that specific case.</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 25 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 25 of the Convention</i>
                                                ],
            within a period of [
                                                <i>three</i>
                                                ] 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 25 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>
                                                2. 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:
                                            </p>
                                            <p>
                                                a) After a case is submitted to arbitration, the competent authority of each
              [
                                                <i>Contracting State</i>
                                                ] shall provide any information that may be
            necessary for the arbitration decision to all panel members without undue delay. Unless
            the competent authorities of the [
                                                <i>Contracting States</i>
                                                ] agree
            otherwise, any information that was not available to both competent authorities before
            the request for arbitration was received by both of them shall not be taken into account
            for purposes of the decision.
                                            </p>
                                            <p>
                                                b) The arbitration panel shall decide the issues submitted to arbitration in
            accordance with the applicable provisions of [
                                                <i>the Convention</i>
                                                ]
            and, subject to these provisions, of those of the domestic laws of the
              [
                                                <i>Contracting States</i>
                                                ]. The panel members shall also consider any
            other sources which the competent authorities of the [
                                                <i>Contracting
              States</i>
                                                ] may by mutual agreement expressly identify.
                                            </p>
                                            <p>
                                                c) The arbitration decision shall be delivered to the competent authorities of
            the [
                                                <i>Contracting States</i>
                                                ] in writing and shall indicate the
            sources of law relied upon and the reasoning which led to its result. The arbitration
            decision shall be adopted by a simple majority of the panel members. 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 24 (Agreement on a Different Resolution) of the MLI</num>
                                        <content>
                                            <p>
                                                2. Notwithstanding paragraph 4 of Article 19 [
                                                <i>of the
            MLI</i>
                                                ], an arbitration decision pursuant to [
                                                <i>Part VI of the
              MLI</i>
                                                ] shall not be binding on the [
                                                <i>Contracting
              States</i>
                                                ] and shall not be implemented if the competent authorities of the
              [
                                                <i>Contracting States</i>
                                                ] agree on a different resolution of all
            unresolved issues within three calendar months after the arbitration decision has been
            delivered to them.
                                            </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 or capital 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 or
            capital 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 Article 28(2)(a) of the MLI, the Hellenic Republic
              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. Τhe Hellenic Republic reserves the right to exclude from the scope of
              [
                                                <i>Part VI</i>
                                                <i>of the MLI</i>
                                                ]
                                                <i> </i>
                                                cases in respect to which
            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 any subsequent regulation. 
                                            </p>
                                            <p>
                                                2. Τhe Hellenic Republic reserves the right to exclude from the scope of
              [
                                                <i>Part VI</i>
                                                <i>of the MLI</i>
                                                ] cases involving the application of domestic
            anti-abuse rules.
                                            </p>
                                            <p>
                                                 3. Τhe Hellenic Republic reserves the right to exclude from the scope of
              [
                                                <i>Part VI</i>
                                                <i>of the MLI</i>
                                                ]
                                                <i> </i>
                                                cases concerning items of
            income or capital that are not taxed by a [
                                                <i>Contracting State</i>
                                                ]
            because they are not included in the taxable base in that [
                                                <i>Contracting
              State</i>
                                                ] or because they are subject to an exemption or zero tax rate
            provided under the domestic tax law of that [
                                                <i>Contracting State</i>
                                                ]. 
                                            </p>
                                            <p>
                                                4. Τhe Hellenic Republic reserves the right to exclude from the scope of
              [
                                                <i>Part VI</i>
                                                <i>of the MLI</i>
                                                ]
                                                <i> </i>
                                                cases involving conduct for
            which the taxpayer or a person acting on behalf of the taxpayer has been found guilty by
            a court for tax fraud or other criminal offense.
                                            </p>
                                        </content>
                                    </article>
                                </chapter>
                            </embeddedStructure>
                        </p>
                    </content>
                </level>
                <article eId="chp_6__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 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. In 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 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="chp_6__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>
                <level>
                    <content>
                        <p>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following paragraph 1 of Article 7 of the MLI applies and supersedes the
        provisions of this Convention:
                                            <authorialNote marker="5" 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
            2022; 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 2022;</p>
                                                <p>and,</p>
                                                <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 the Convention by the
            Hellenic Republic:</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
            2022; and</p>
                                                <p>b) with respect to all other taxes levied by the Hellenic Republic, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2022.</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 or capital 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>
                    </content>
                </level>
            </chapter>
            <chapter eId="chp_7">
                <num>Chapter VII</num>
                <heading>Final provisions</heading>
                <article eId="chp_7__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 in both
        Contracting States:</p>
                        <p>a) in respect of taxes withheld at source, to income derived 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 year beginning on or after 1 January in the calendar year next following the
        year in which the Convention enters into force.</p>
                    </content>
                </article>
                <article eId="chp_7__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 5 years from the date on which the Convention enters into
        force. In such event, the Convention shall cease to have effect in both Contracting
        States:</p>
                        <p>a) in respect of taxes withheld at source, to income derived 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 year 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 Athens this 21 day of January 1980, in the English
        language.</p>
                    </content>
                </article>
            </chapter>
        </mainBody>
    </doc>
</akomaNtoso>
