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        <preface>
            <p>
                <docNumber>89-90/1998</docNumber>
                <docTitle>Agreement between the Republic of Finland and the State of Israel for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital</docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE AGREEMENT BETWEEN THE REPUBLIC OF FINLAND AND THE STATE OF ISRAEL FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL</heading>
                        <p>This document presents the synthesised text for the application of the Agreement
      between the Republic of Finland and the State of Israel for the avoidance of double taxation
      and the prevention of fiscal evasion with respect to taxes on income and on capital signed on
      8 January 1997 (the “Agreement”), 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 State of Israel 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
      State of Israel submitted to the Depositary upon ratification on 13 September 2018. 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 Agreement. The document also contains the
      modifications resulting from the withdrawal of the reservation made by the Republic of Finland
      to Article 9 of the MLI (consolidated MLI position of the Republic of Finland on 27 June
      2023).</p>
                        <p>The authentic legal texts of the Agreement 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
      Agreement are included in boxes throughout the text of this document in the context of the
      relevant provisions of the Agreement. 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 Agreement (such as “Covered Tax
      Agreement” and “Agreement”, “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.</p>
                        <p>In all cases, references made to the provisions of the Agreement or to the Agreement
      must be understood as referring to the Agreement 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 Agreement do not take effect on the same
      dates as the original provisions of the Agreement. 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 State of
      Israel 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 13 September 2018 for the State of
      Israel.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 January
      2019 for the State of Israel.</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 Agreement 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 State of Israel
      submitted to the Depositary upon ratification on 13 September 2018 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>
                        </p>
                        <p>
                            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
      State of Israel is published in the Treaty Series of the Statute Book of Finland SopS 35/2019.
      Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2019/20190035">https://finlex.fi/fi/sopimukset/sopsteksti/2019/20190035</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190035.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190035.pdf</a>
                        </p>
                        <p>
                            Agreement between the Republic of Finland and the State of Israel for the avoidance of
      double taxation and the prevention of fiscal evasion with respect to taxes on income and on
      capital signed at Helsinki on 8 January 1997, corresponding to the 29th day of Tevet 5757 is
      published in the Treaty Series of the Statute Book of Finland SopS 90/1998. Link to Finnish
      language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1998/19980090">https://www.finlex.fi/fi/sopimukset/sopsteksti/1998/19980090</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Agreement between the Republic of Finland and the State of Israel for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital</p>
            <p>The Government of the Republic of Finland and the Government of the State of
    Israel,</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 an Agreement for the avoidance of double taxation and the
      prevention of fiscal evasion 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 Agreement:
                                <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 to the application of this Agreement by
          the Republic of Finland:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          non-residents, where the event giving rise to such taxes occurs on or after 1 January
          2020; and</p>
                                    <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2020;</p>
                                    <p>and,</p>
                                    <p>In accordance with paragraphs 1, 2 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 Agreement by the
          State of Israel:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          non-residents, where the event giving rise to such taxes occurs on or after the first day
          of the taxable period that begins on or after 1 June 2019; and</p>
                                    <p>b) with respect to all other taxes levied by the State of Israel, for taxes levied
          with respect to taxable periods beginning on or after 1 January 2020.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 6 OF THE MLI – PURPOSE OF A COVERED TAX AGREEMENT</num>
                        <content>
                            <p>
                                Intending to eliminate double taxation with respect to the taxes covered by
          [
                                <i>this Agreement</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 Agreement</i>
                                ]
        for the indirect benefit of residents of third jurisdictions),
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <p>Have agreed as follows:</p>
        </preamble>
        <mainBody>
            <article eId="art_1">
                <num>Article 1</num>
                <heading>Persons covered</heading>
                <content>
                    <p>This Agreement shall apply to persons who are residents of one or both of the
      Contracting States.</p>
                </content>
            </article>
            <article eId="art_2">
                <num>Article 2</num>
                <heading>Taxes covered</heading>
                <content>
                    <p>1. This Agreement 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, taxes on the total amounts of
      wages or salaries paid by enterprises, as well as taxes on capital appreciation.</p>
                    <p>3. The existing taxes to which the Agreement shall apply are:</p>
                    <p>a) in Finland:</p>
                    <p>(i) the state income taxes;</p>
                    <p>(ii) the corporate income tax;</p>
                    <p>(iii) the communal tax on income;</p>
                    <p>(iv) the church tax on income; </p>
                    <p>(v) the tax withheld at source from interest;</p>
                    <p>(vi) the tax withheld at source from non-residents' income; and</p>
                    <p>(vii) the state capital tax;</p>
                    <p>(hereinafter referred to as "Finnish tax");</p>
                    <p>b) in Israel:</p>
                    <p>(i) the income tax (including the capital gains tax);</p>
                    <p>(ii) the company tax;</p>
                    <p>(iii) the tax imposed upon the alienation of immovable property under the Land
      Appreciation Tax Law; and</p>
                    <p>(iv) the national property tax;</p>
                    <p>(hereinafter referred to as "Israeli tax").</p>
                    <p>4. The Agreement shall apply also to any identical or substantially similar taxes
      which are imposed after the date of signature of the Agreement in addition to, or in place of,
      the existing taxes. The competent authorities of the Contracting States shall notify each
      other of any significant changes which have been made in their respective taxation
      laws.</p>
                </content>
            </article>
            <article eId="art_3">
                <num>Article 3</num>
                <heading>General definitions</heading>
                <content>
                    <p>1. For the purposes of this Agreement, unless the context otherwise
      requires:</p>
                    <p>a) the term "person" includes an individual, a company and any other body of
      persons;</p>
                    <p>b) the term "company" means any body corporate or any entity that is treated as a body
      corporate for tax purposes;</p>
                    <p>c) 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>d) the term "national" means:</p>
                    <p>(i) any individual possessing the nationality of a Contracting State;</p>
                    <p>(ii) any legal person, partnership or association deriving its status as such from the
      laws in force in a Contracting State;</p>
                    <p>e) the term "international traffic" means any transport by a ship or aircraft operated
      by an enterprise of a Contracting State, except when the ship or aircraft is operated solely
      between places in the other Contracting State;</p>
                    <p>f) the term "competent authority" means:</p>
                    <p>(i) in Finland, the Ministry of Finance, its authorised representative or the
      authority which, by the Ministry of Finance, is designated as competent authority;</p>
                    <p>(ii) in Israel, the Minister of Finance or his authorised representative.</p>
                    <p>2. As regards the application of the Agreement at any time by a Contracting State, any
      term not defined therein shall, unless the context otherwise requires, have the meaning that
      it has at that time under the law of that State for the purposes of the taxes to which the
      Agreement applies, any meaning under the applicable tax laws of that State prevailing over a
      meaning given to the term under other laws of that State.</p>
                </content>
            </article>
            <article eId="art_4">
                <num>Article 4</num>
                <heading>Residence</heading>
                <content>
                    <p>1. For the purposes of this Agreement, 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, place of incorporation (registration) or any other
      criterion of a similar nature, and also includes that State and any statutory body or local
      authority thereof. This term, however, 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 States, then his status shall be determined as follows:</p>
                    <p>a) he shall be deemed to be a resident only 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 only 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 only 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, the competent authorities of the Contracting States
      shall settle the question by mutual agreement and determine the mode of application of the
      Agreement to such person. In so settling and determining the status of that person other than
      an individual, consideration shall be given to the rules contained in paragraph 3 of Article 4
      of the OECD Model Tax Convention, adopted in 1992 (as amended from time to time), especially
      to the reference concerning the place of effective management, and to the fact where the
      central management and control is exercised.</p>
                </content>
            </article>
            <article eId="art_5">
                <num>Article 5</num>
                <heading>Permanent establishment</heading>
                <content>
                    <p>1. For the purposes of this Agreement, 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. The term "permanent establishment" shall be deemed likewise to
      encompass:</p>
                    <p>a) a building site or construction or installation project only if it lasts more than
      twelve months;</p>
                    <p>b) the maintenance, for a period of more than six months, of machinery or equipment
      for the purpose of rental (except where the provisions of paragraph 2 of Article 8
      apply).</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 a resident of the other Contracting State, or which carries
      on business in that other State (whether through a permanent establishment or otherwise),
      shall not of itself constitute either company a permanent establishment of the
      other.</p>
                </content>
            </article>
            <article eId="art_6">
                <num>Article 6</num>
                <heading>Income from immovable property</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State from immovable property
      (including income from agriculture or forestry) situated in the other Contracting State may be
      taxed in that other State.</p>
                    <p>2. 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 buildings, 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 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>
                </content>
            </article>
            <article eId="art_7">
                <num>Article 7</num>
                <heading>Business profits</heading>
                <content>
                    <p>1. The profits of an enterprise of a Contracting State shall be taxable only in that
      State unless the enterprise carries on business in the other Contracting State through a
      permanent establishment situated therein. If the enterprise carries on business as aforesaid,
      the profits of the enterprise may be taxed in the other State but only so much of them as is
      attributable to that permanent establishment.</p>
                    <p>2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting
      State carries on business in the other Contracting State through a permanent establishment
      situated therein, there shall in each Contracting State be attributed to that permanent
      establishment the profits which it might be expected to make if it were a distinct and
      separate enterprise engaged in the same or similar activities under the same or similar
      conditions and dealing wholly independently with the enterprise of which it is a permanent
      establishment.</p>
                    <p>3. In determining the profits of a permanent establishment, there shall be allowed as
      deductions expenses which are incurred for the purposes of the permanent establishment,
      including executive and general administrative expenses so incurred, whether in the State in
      which the permanent establishment is situated or elsewhere.</p>
                    <p>4. Insofar as it has been customary in a Contracting State to determine the profits to
      be attributed to a permanent establishment on the basis of an apportionment of the total
      profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that
      Contracting State from determining the profits to be taxed by such an apportionment as may be
      customary. The method of apportionment adopted shall, however, be such that the result shall
      be in accordance with the principles contained in this Article.</p>
                    <p>5. No profits shall be attributed to a permanent establishment by reason of the mere
      purchase by that permanent establishment of goods or merchandise for the
      enterprise.</p>
                    <p>6. For the purposes of the preceding paragraphs, the profits to be attributed to the
      permanent establishment shall be determined by the same method year by year unless there is
      good and sufficient reason to the contrary.</p>
                    <p>7. Where profits include items of income which are dealt with separately in other
      Articles of this Agreement, then the provisions of those Articles shall not be affected by the
      provisions of this Article.</p>
                </content>
            </article>
            <article eId="art_8">
                <num>Article 8</num>
                <heading>Shipping and air transport</heading>
                <content>
                    <p>1. Profits of an enterprise of a Contracting State from the operation of ships or
      aircraft in international traffic shall be taxable only in that State.</p>
                    <p>2. Profits of an enterprise of a Contracting State from the use, maintenance or rental
      of containers (including trailers, barges and related equipment for the transport of
      containers) used for the transport of goods or merchandise shall be taxable only in that
      State, except where such containers are used for the transport of goods or merchandise solely
      between places within the other Contracting State.</p>
                    <p>3. The provisions of paragraphs 1 and 2 shall also apply to profits from the
      participation in a pool, a joint business or an international operating agency.</p>
                </content>
            </article>
            <article eId="art_9">
                <num>Article 9</num>
                <heading>Associated enterprises</heading>
                <content>
                    <p>1. Where</p>
                    <p>a) an enterprise of a Contracting State participates directly or indirectly in the
      management, control or capital of an enterprise of the other Contracting State, or</p>
                    <p>b) the same persons participate directly or indirectly in the management, control or
      capital of an enterprise of a Contracting State and an enterprise of the other Contracting
      State,</p>
                    <p>and in either case conditions are made or imposed between the two enterprises in their
      commercial or financial relations which differ from those which would be made between
      independent enterprises, then any profits which would, but for those conditions, have accrued
      to one of the enterprises, but, by reason of those conditions, have not so accrued, may be
      included in the profits of that enterprise and taxed accordingly.</p>
                    <p>2. Where a Contracting State includes in the profits of an enterprise of that State –
      and taxes accordingly – profits on which an enterprise of the other Contracting State has been
      charged to tax in that other State and the profits so included are profits which would have
      accrued to the enterprise of the first-mentioned State if the conditions made between the two
      enterprises had been those which would have been made between independent enterprises, then
      that other State shall make an appropriate adjustment to the amount of tax charged therein on
      those profits, where that other State considers the adjustment justified. In determiing such
      adjustment, due regard shall be had to the other provisions of this Agreement and the
      competent authorities of the Contracting States shall if necessary consult each
      other.</p>
                </content>
            </article>
            <article eId="art_10">
                <num>Article 10</num>
                <heading>Dividends</heading>
                <content>
                    <p>1. Dividends paid by a company which is a resident of a Contracting State to a
      resident of the other Contracting State may be taxed in that other State. However, such
      dividends may also be taxed in the Contracting State of which the company paying the dividends
      is a resident and according to the laws of that State, but if the beneficial owner of the
      dividends is a resident of the other Contracting State, the tax so charged shall not
      exceed:</p>
                    <p>a) 5 per cent of the gross amount of the dividends if the beneficial owner is a
      company (other than a partnership) which controls directly at least 10 per cent of the voting
      power in the company paying the dividends;</p>
                    <p>b) 15 per cent of the gross amount of the dividends in all other cases.</p>
                    <p>2. a) Notwithstanding the provisions of paragraph 1, as long as an individual resident
      in Finland is under Finnish tax law entitled to a tax credit in respect of dividends paid by a
      company resident in Finland, dividends paid by a company which is a resident of Finland to a
      resident of Israel shall be taxable only in Israel if the beneficial owner of the dividends is
      a resident of Israel.</p>
                    <p>b) Notwithstanding the provisions of sub-paragraph a) of paragraph 1, dividends paid
      by a company which is a resident of Israel to a resident of Finland may be taxed in Israel and
      according to Israeli law, but if the beneficial owner of the dividends is a company which is a
      resident of Finland and which holds directly at least 10 per cent of the voting power in the
      company paying the dividends, the tax so charged shall not exceed:</p>
                    <p>(i) 10 per cent of the gross amount of the dividends, if the dividends are paid out of
      profits which, by virtue of provisions in Israeli law for the encouragement of investment in
      Israel, are exempted from tax or subject to tax at a rate that is lower than the standard rate
      levied on the profits of a company resident in Israel;</p>
                    <p>(ii) 5 per cent of the gross amount of the dividends in all other cases.</p>
                    <p>3. The provisions of paragraphs 1 and 2 shall not affect the taxation of the company
      in respect of the profits out of which the dividends are paid.</p>
                    <p>4. The term "dividends" as used in this Article means income from shares, or other
      rights, not being debt-claims, participating in profits, as well as income from other
      corporate rights which is subjected to the same taxation treatment as income from shares by
      the laws of the State of which the company making the distribution is a resident.</p>
                    <p>5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      dividends, being a resident of a Contracting State, carries on business in the other
      Contracting State of which the company paying the dividends is a resident, through a permanent
      establishment situated therein, or performs in that other State independent personal services
      from a fixed base situated therein, and the holding in respect of which the dividends are paid
      is effectively connected with such permanent establishment or fixed base. In such case the
      provisions of Article 7 or Article 14, as the case may be, shall apply.</p>
                    <p>6. 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>
                    <p>7. Notwithstanding the provisions of this Article and of paragraph 2 of Article 24,
      where a company which is a resident of a Contracting State carries on business in the other
      Contracting State through a permanent establishment situated therein, the profits of that
      permanent establishment may, after being subjected to the corporation tax, be subjected in
      accordance with the domestic laws of that other State to tax at a rate which shall not
      exceed:</p>
                    <p>a) 10 per cent where a rate of company tax lower than the regular rate has been
      applied;</p>
                    <p>b) 5 per cent in all other cases.</p>
                </content>
            </article>
            <article eId="art_11">
                <num>Article 11</num>
                <heading>Interest</heading>
                <content>
                    <p>1. Interest arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such interest may also be taxed in the Contracting State in which it
      arises and according to the laws of that State, but if the beneficial owner of the interest is
      a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of
      the gross amount of the interest.</p>
                    <p>3. A resident of a Contracting State may elect to be taxed in the other Contracting
      State in which the interest arises, in lieu of the taxation referred to in paragraph 2, on the
      net amount of the interest. In that case, the rate of tax in paragraph 2 shall not apply. The
      competent authority of that other State may adopt reasonable rules for the determination and
      reporting of such income.</p>
                    <p>4. Notwithstanding the provisions of paragraphs 2 and 3,</p>
                    <p>a) interest arising in Israel shall be taxable only in Finland if the interest is paid
      to:</p>
                    <p>(i) the State of Finland, or a local authority or a statutory body thereof;</p>
                    <p>(ii) the Bank of Finland;</p>
                    <p>(iii) the Finnish Fund for Industrial Co-operation Ltd (FINNFUND) or any other similar
      institution, as may be agreed from time to time between the competent authorities of the
      Contracting States;</p>
                    <p>b) interest arising in Finland shall be taxable only in Israel if the interest is paid
      to: </p>
                    <p>(i) the State of Israel, a local authority therein or a governmental
      institution;</p>
                    <p>(ii) the Bank of Israel;</p>
                    <p>(iii) any public institution, as may be agreed from time to time between the competent
      authorities of the Contracting States;</p>
                    <p>c) interest arising in a Contracting State on a loan guaranteed by any of the bodies
      mentioned or referred to in sub-paragraph a) or sub-paragraph b) and paid to a resident of the
      other Contracting State shall be taxable only in that other State.</p>
                    <p>5. The term "interest" as used in this Article means income from debt-claims of every
      kind, whether or not secured by mortgage and whether or not carrying a right to participate in
      the debtor's profits, and in particular, income from government securities and income from
      bonds or debentures, including premiums and prizes attaching to such securities, bonds or
      debentures, and linkage differentials. Penalty charges for late payment shall not be regarded
      as interest for the purpose of this Article.</p>
                    <p>6. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of
      the interest, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the interest arises, through a permanent establishment situated
      therein, or performs in that other State independent personal services from a fixed base
      situated therein, and the debt-claim in respect of which the interest is paid is effectively
      connected with such permanent establishment or fixed base. In such case the provisions of
      Article 7 or Article 14, as the case may be, shall apply.</p>
                    <p>7. Interest shall be deemed to arise in a Contracting State when the payer is a
      resident of that State. Where, however, the person paying the interest, whether 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 State in which the permanent establishment or fixed
      base is situated.</p>
                    <p>8. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the interest, having regard
      to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon
      by the payer and the beneficial owner in the absence of such relationship, the provisions of
      this Article shall apply only to the last-mentioned amount. In such case, the excess part of
      the payments shall remain taxable according to the laws of each Contracting State, due regard
      being had to the other provisions of this Agreement.</p>
                </content>
            </article>
            <article eId="art_12">
                <num>Article 12</num>
                <heading>Royalties</heading>
                <content>
                    <p>1. Royalties arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such royalties may also be taxed in the Contracting State in which they
      arise and according to the laws of that State, but if the beneficial owner of the royalties is
      a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of
      the gross amount of the royalties.</p>
                    <p>3. The term "royalties" as used in this Article means payments of any kind received as
      a consideration for the use of, or the right to use, any copyright of literary, artistic or
      scientific work including computer software, cinematograph films, and films or tapes for
      television or radio broadcasting, any patent, trade mark, design or model, plan, secret
      formula or process, or for information concerning industrial, commercial or scientific
      experience.</p>
                    <p>4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      royalties, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the royalties arise, through a permanent establishment situated
      therein, or performs in that other State independent personal services from a fixed base
      situated therein, and the right or property in respect of which the royalties are paid is
      effectively connected with such permanent establishment or fixed base. In such case the
      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 a
      resident of that State. Where, however, the person paying the royalties, whether he is a
      resident of a Contracting State or not, has in a Contracting State a permanent establishment
      or a fixed base in connection with which the liability to pay the royalties was incurred, and
      such royalties are borne by such permanent establishment or fixed base, then such royalties
      shall be deemed to arise in the State in which the permanent establishment or fixed base is
      situated.</p>
                    <p>6. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the royalties, having
      regard to the use, right or information for which they are paid, exceeds the amount which
      would have been agreed upon by the payer and the beneficial owner in the absence of such
      relationship, the provisions of this Article shall apply only to the last-mentioned amount. In
      such case, the excess part of the payments shall remain taxable according to the laws of each
      Contracting State, due regard being had to the other provisions of this Agreement.</p>
                </content>
            </article>
            <article eId="art_13">
                <num>Article 13</num>
                <heading>Capital gains</heading>
                <content>
                    <p>1. Gains derived by a resident of a Contracting State from the alienation of immovable
      property referred to in paragraph 2 of Article 6 and situated in the other Contracting State
      may be taxed in that other State.</p>
                    <p>2. The term "immovable property" as used in this Article includes shares or other
      corporate rights, as well as any other rights, in a real estate company (being a company 50
      per cent or more of the market value of the assets of which consist of immovable property
      whether owned directly or indirectly by the company, or rights in immovable property). Such
      shares or rights shall be deemed to be situated in the Contracting State in which the
      immovable property giving rise to such capital gain is situated.</p>
                    <p>3. Gains derived by a resident of a Contracting State from the sale, exchange or other
      disposition, directly or indirectly, of shares in a company which is a resident of the other
      Contracting State, may be taxed in that other State, but only if the resident of the
      first-mentioned State owned either directly or indirectly at any time within the twelve-month
      period preceding such sale, exchange or other disposition, shares giving the right to 10 per
      cent or more of the voting power in the company. However, the tax charged in that other State
      shall not exceed 20 per cent of such gains. For the purposes of this paragraph, indirect
      ownership shall be deemed to include, but not be limited to, ownership by a related
      person.</p>
                    <p>4. 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>5. Gains derived by an enterprise of a Contracting State from the alienation of ships
      or aircraft operated in international traffic or movable property pertaining to the operation
      of such ships or aircraft, shall be taxable only in that State.</p>
                    <p>6. Gains derived by an enterprise of a Contracting State from the alienation of
      containers (including trailers, barges and related equipment for the transport of containers)
      used for the transport of goods or merchandise shall be taxable only in that State, except
      where such containers are used for the transport of goods or merchandise solely between places
      within the other Contracting State.</p>
                    <p>7. 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>
                    <p>
                        <embeddedStructure class="mli-replacement">
                            <p>
                                <authorialNote>
                                    <p>
                                        The following paragraph 4 of Article 9 of the MLI applies and supersedes the
        provisions of this Agreement:
                                        <authorialNote marker="2" placement="bottom">
                                            <p>In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of
            the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the application
            of this Agreement by the Republic of Finland: </p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            non-residents, where the event giving rise to such taxes occurs on or after 1 January
            2024; and</p>
                                            <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2024;</p>
                                            <p>and,</p>
                                            <p>In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of
            the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the application
            of the Agreement by the State of Israel: </p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            non-residents, where the event giving rise to such taxes occurs on or after 1 January
            2024; and</p>
                                            <p>b) with respect to all other taxes levied by the State of Israel, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2024.</p>
                                        </authorialNote>
                                    </p>
                                </authorialNote>
                            </p>
                            <article>
                                <num>ARTICLE 9 OF THE MLI – CAPITAL GAINS FROM ALIENATION OF SHARES OR INTERESTS OF ENTITIES DERIVING THEIR VALUE PRINCIPALLY FROM IMMOVABLE PROPERTY</num>
                                <content>
                                    <p>
                                        For purposes of [
                                        <i>the Agreement</i>
                                        ], gains derived by a
          resident of a [
                                        <i>Contracting State</i>
                                        ] from the alienation of shares or
          comparable interests, such as interests in a partnership or trust, may be taxed in the
          other [
                                        <i>Contracting State</i>
                                        ] if, at any time during the 365 days
          preceding the alienation, these shares or comparable interests derived more than 50 per
          cent of their value directly or indirectly from immovable property (real property)
          situated in that other [
                                        <i>Contracting State</i>
                                        ].
                                    </p>
                                </content>
                            </article>
                        </embeddedStructure>
                    </p>
                </content>
            </article>
            <article eId="art_14">
                <num>Article 14</num>
                <heading>Independent personal services</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State in respect of professional
      services or other activities of an independent character shall be taxable only in that State
      unless he has a fixed base regularly available to him in the other Contracting State for the
      purpose of performing his activities. If he has such a fixed base, the income may be taxed in
      the other State but only so much of it as is attributable to that fixed base.</p>
                    <p>2. The term "professional services" includes especially independent scientific,
      literary, artistic, educational or teaching activities as well as the independent activities
      of physicians, lawyers, engineers, architects, dentists and accountants.</p>
                </content>
            </article>
            <article eId="art_15">
                <num>Article 15</num>
                <heading>Dependent personal services</heading>
                <content>
                    <p>1. Subject to the provisions of Articles 16, 18, 19 and 20, salaries, wages and other
      similar remuneration derived by a resident of a Contracting State in respect of an employment
      shall be taxable only in that State unless the employment is exercised in the other
      Contracting State. If the employment is so exercised, such remuneration as is derived
      therefrom may be taxed in that other State.</p>
                    <p>2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident
      of a Contracting State in respect of an employment exercised in the other Contracting State
      shall be taxable only in the first-mentioned State if:</p>
                    <p>a) the recipient is present in the other State for a period or periods not exceeding
      in the aggregate 183 days within any twelve-month period commencing or ending in the calendar
      year concerned, and</p>
                    <p>b) the remuneration is paid by, or on behalf of, an employer who is not a resident of
      the other State, and</p>
                    <p>c) the remuneration is not borne by a permanent establishment 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
      by an enterprise of a Contracting State, may be taxed in that State.</p>
                </content>
            </article>
            <article eId="art_16">
                <num>Article 16</num>
                <heading>Directors' fees</heading>
                <content>
                    <p>Directors' fees and other similar payments derived by a resident of a Contracting
      State in his capacity as a member of the board of directors or any other similar organ of a
      company which is a resident of the other Contracting State may be taxed in that other
      State.</p>
                </content>
            </article>
            <article eId="art_17">
                <num>Article 17</num>
                <heading>Artistes and sportsmen</heading>
                <content>
                    <p>1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident
      of a Contracting State as an entertainer, such as a theatre, motion picture, radio or
      television artiste, or a musician, or as a sportsman, 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 a
      sportsman in his capacity as such accrues not to the entertainer or sportsman 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 sportsman are
      exercised.</p>
                </content>
            </article>
            <article eId="art_18">
                <num>Article 18</num>
                <heading>Pensions, annuities and similar payments</heading>
                <content>
                    <p>1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar
      remuneration in consideration of past employment, or any annuity, paid to a resident of a
      Contracting State 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 paid and other benefits, whether paid periodically or in a
      lump-sum, granted under the social security legislation of a Contracting State or under any
      public scheme organised by a Contracting State for social welfare purposes, or any annuity
      arising in a Contracting State, may be taxed in that State.</p>
                    <p>3. The term "annuity" as used in this Article means a stated sum payable periodically
      at stated times during life, or during a specified or ascertainable period of time, under an
      obligation to make the payments in return for adequate and full consideration in money or
      money's worth (other than services rendered).</p>
                </content>
            </article>
            <article eId="art_19">
                <num>Article 19</num>
                <heading>Government service</heading>
                <content>
                    <p>1. a) Salaries, wages and other similar remuneration, other than a pension, paid by a
      Contracting State or a statutory 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 salaries, wages and other similar 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
      statutory 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, 17 and 18 shall apply to salaries, wages and
      other similar remuneration, and to pensions, in respect of services rendered in connection
      with a business carried on by a Contracting State or a statutory body or a local authority
      thereof.</p>
                </content>
            </article>
            <article eId="art_20">
                <num>Article 20</num>
                <heading>Students and trainees</heading>
                <content>
                    <p>1. Payments which a student, or an apprentice or business, technical, agricultural or
      forestry trainee, who is or was immediately before visiting a Contracting State a resident of
      the other Contracting State and who is present in the first-mentioned State solely for the
      purpose of 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 an apprentice or business, technical, agricultural or forestry trainee,
      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 continuous
      period not exceeding 183 days, 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="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 Agreement 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>
            <article eId="art_22">
                <num>Article 22</num>
                <heading>Capital</heading>
                <content>
                    <p>1. Capital represented by immovable property referred to in paragraph 2 of Article 6,
      owned by a resident of a Contracting State and situated in the other Contracting State, may be
      taxed in that other State. The term "immovable property" shall also include shares and rights
      referred to in paragraph 2 of Article 13, and those shares and rights shall be deemed to be
      situated in the Contracting State in which the immmovable property from which they derive
      their value is situated.</p>
                    <p>2. Capital represented by movable property forming part of the business property of a
      permanent establishment which an enterprise of a Contracting State has in the other
      Contracting State or by movable property pertaining to a fixed base available to a resident of
      a Contracting State in the other Contracting State for the purpose of performing independent
      personal services, may be taxed in that other State.</p>
                    <p>3. Capital represented by ships and aircraft operated in international traffic by a
      resident of a Contracting State, and by movable property pertaining to the operation of such
      ships and aircraft, shall be taxable only in that State.</p>
                    <p>4. Capital represented by containers (including trailers, barges and related equipment
      for the transport of containers) used by a resident of a Contracting State for the transport
      of goods or merchandise shall be taxable only in that State, except where such containers are
      used for the transport of goods or merchandise solely between places within the other
      Contracting State.</p>
                    <p>5. All other elements of capital of a resident of a Contracting State shall be taxable
      only in that State.</p>
                </content>
            </article>
            <article eId="art_23">
                <num>Article 23</num>
                <heading>Elimination of double taxation</heading>
                <content>
                    <p>1. Subject to the provisions of Finnish law regarding the elimination of international
      double taxation (which shall not affect the general principle hereof), double taxation shall
      be eliminated in Finland as follows:</p>
                    <p>a) Where a resident of Finland derives income or owns capital which, in accordance
      with the provisions of this Agreement, may be taxed in Israel, Finland shall, subject to the
      provisions of sub-paragraph b), allow:</p>
                    <p>(i) as a deduction from the Finnish income tax of that person, an amount equal to the
      Israeli income tax paid under Israeli law and in accordance with the Agreement, as computed by
      reference to the same income by reference to which the Finnish tax is computed;</p>
                    <p>(ii) as a deduction from the Finnish capital tax of that person, an amount equal to
      the Israeli capital tax paid under Israeli law and in accordance with the Agreement, as
      computed by reference to the same capital by reference to which the Finnish tax is
      computed.</p>
                    <p>b) Dividends paid by a company being a resident of Israel to a company which is a
      resident of Finland and which controls directly at least 10 per cent of the voting power in
      the company paying the dividends shall be exempt from Finnish tax.</p>
                    <p>c) For the purposes of sub-paragraph a), the term "Israeli income tax paid" shall be
      deemed to include any amount which would have been payable as Israeli tax, in accordance with
      the provisions of the Agreement, for any year but for a deduction allowed in ascertaining the
      taxable income or an exemption from, or reduction of, tax granted for that year or any part
      thereof under:</p>
                    <p>(i) the Law for the Encouragement of Capital Investments, 1959, the Law for the
      Encouragement of Industry (Taxes), 1969, the Law for the Encouragement of Capital Investments
      in Agriculture, 1981, and the Law for the Encouragement of Investments (Capital Intensive
      Companies), 1990, and their adjunct laws (as amended from time to time without affecting the
      general principle thereof); or</p>
                    <p>(ii) any other provision which may be enacted after the date of signature of the
      Agreement granting an exemption from, or reduction of, tax which is agreed by the competent
      authorities of the Contracting States to be of substantially similar character (as amended
      from time to time without affecting the general principle thereof).</p>
                    <p>d) The provisions of sub-paragraph c) shall apply for the first ten years for which
      the Agreement is effective. However, the competent authorities of the Contracting States may
      consult each other in order to determine whether such period shall be extended.</p>
                    <p>2. In Israel double taxation shall be eliminated as follows:</p>
                    <p>Where a resident of Israel derives income or owns capital which, in accordance with
      the provisions of this Agreement, may be taxed in Finland, Israel shall allow:</p>
                    <p>a) as a deduction from the tax on the income of that resident, an amount equal to the
      income tax paid in Finland;</p>
                    <p>b) as a deduction from the tax on the capital of that resident, an amount equal to the
      capital tax paid in Finland.</p>
                    <p>Such deduction in either case shall not, however, exceed that part of the income tax
      or capital tax, as computed before the deduction is given, which is attributable, as the case
      may be, to the income or the capital which may be taxed in Finland.</p>
                    <p>3. Where in accordance with any provision of the Agreement income derived or capital
      owned by a resident of a Contracting State is exempt from tax in that State, such State 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>
                </content>
            </article>
            <article eId="art_24">
                <num>Article 24</num>
                <heading>Non-discrimination</heading>
                <content>
                    <p>1. Nationals of a Contracting State shall not be subjected in the other Contracting
      State to any taxation or any requirement connected therewith, which is other or more
      burdensome than the taxation and connected requirements to which nationals of that other State
      in the same circumstances, in particular with respect to residence, are or may be subjected.
      This provision shall, notwithstanding the provisions of Article 1, also apply to persons who
      are not residents of one or both of the Contracting States.</p>
                    <p>2. The taxation on a permanent establishment which an enterprise of a Contracting
      State has in the other Contracting State shall not be less favourably levied in that other
      State than the taxation levied on enterprises of that other State carrying on the same
      activities. This provision shall not be construed as obliging a Contracting State to grant to
      residents of the other Contracting State any personal allowances, reliefs and reductions for
      taxation purposes on account of civil status or family responsibilities which it grants to its
      own residents.</p>
                    <p>3. Except where the provisions of paragraph 1 of Article 9, paragraph 8 of Article 11,
      or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an
      enterprise of a Contracting State to a resident of the other Contracting State shall, for the
      purpose of determining the taxable profits of such enterprise, be deductible under the same
      conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any
      debts of an enterprise of a Contracting State to a resident of the other Contracting State
      shall, for the purpose of determining the taxable capital of such enterprise, be deductible
      under the same conditions as if they had been contracted to a resident of the first-mentioned
      State.</p>
                    <p>4. Enterprises of a Contracting State, the capital of which is wholly or partly owned
      or controlled, directly or indirectly, by one or more residents of the other Contracting
      State, shall not be subjected in the first-mentioned State to any taxation or any requirement
      connected therewith which is other or more burdensome than the taxation and connected
      requirements to which other similar enterprises of the first-mentioned State are or may be
      subjected.</p>
                    <p>5. The provisions of this Article shall, notwithstanding the provisions of Article 2,
      apply to taxes of every kind and description.</p>
                </content>
            </article>
            <article eId="art_25">
                <num>Article 25</num>
                <heading>Limitation on benefits</heading>
                <content>
                    <p>1. A person that is a resident of a Contracting State and derives income from the
      other Contracting State shall be entitled, in that other State, to benefits of this Agreement
      only if such person is:</p>
                    <p>a) an individual;</p>
                    <p>b) (i) a person, more than fifty per cent of the beneficial interest in which (or in
      the case of a company, more than fifty per cent of the rights to any of the following: votes
      in a general meeting; distribution of profits; distribution of assets upon liquidation) is
      owned or controlled directly or indirectly, by persons entitled to the benefits of the
      Agreement under sub-paragraph a) or sub-paragraph c); and</p>
                    <p>(ii) a person, more than fifty per cent of the gross income of which is not used,
      directly or indirectly, to meet liabilities (including liabilities for interest or royalties)
      to persons not entitled to the benefits;</p>
                    <p>c) a company in whose principal class of shares there is substantial and regular
      trading on a recognised stock exchange in either of the Contracting States; or</p>
                    <p>d) engaged in the active conduct of a trade or business in the first-mentioned
      Contracting State (other than the business of making or managing investments, unless these
      activities are banking or insurance activities carried on by a bank or insurance company), and
      the income derived from the other Contracting State is derived in connection with, or is
      incidental to, that trade or business.</p>
                    <p>2. In addition to the provisions of paragraph 1, the competent authorities of the
      Contracting States, upon mutual agreement, may:</p>
                    <p>a) deny the benefits of the Agreement to any person, or with respect to any
      transaction, if in their opinion the granting of those benefits, under the circumstances,
      would constitute an abuse of the Agreement according to its purpose, or</p>
                    <p>b) grant the benefits of the Agreement to any person otherwise not entitled thereto by
      virtue of paragraph 1.</p>
                </content>
            </article>
            <article eId="art_26">
                <num>Article 26</num>
                <heading>Mutual agreement procedure</heading>
                <content>
                    <p>1. Where a person considers that the actions of one or both of the Contracting States
      result or will result for him in taxation not in accordance with the provisions of this
      Agreement, 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
      Agreement.</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 Agreement. 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 Agreement. They may also consult together for the elimination of double taxation in cases
      not provided for in the Agreement.</p>
                    <p>4. The competent authorities of the Contracting States may communicate with each other
      directly, including through a joint commission consisting of themselves or their
      representatives, for the purpose of reaching an agreement in the sense of the preceding
      paragraphs.</p>
                </content>
            </article>
            <article eId="art_27">
                <num>Article 27</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 Agreement or of the domestic laws of
      the Contracting States concerning taxes covered by the Agreement insofar as the taxation
      thereunder is not contrary to the Agreement. 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)
      concerned with 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 Agreement. 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="art_28">
                <num>Article 28</num>
                <heading>Members of diplomatic missions and consular posts</heading>
                <content>
                    <p>Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic
      missions or consular posts under the general rules of international law or under the
      provisions of special agreements.</p>
                </content>
            </article>
            <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 Agreement:
                                <authorialNote marker="3" placement="bottom">
                                    <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
          Article 7 of the MLI has effect with respect to the application of this Convention by the
          Republic of Finland:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2020;
          and</p>
                                    <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2020;</p>
                                    <p>and,</p>
                                    <p>In accordance with paragraphs 1, 2 and 3 of Article 35 of the MLI, paragraph 1 of
          Article 7 of the MLI has effect with respect to the application by the Convention by the
          State of Israel:</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 the first day
          of the taxable period that begins on or after 1 June 2019; and</p>
                                    <p>b) with respect to all other taxes levied by the State of Israel, for taxes levied
          with respect to taxable periods beginning on or after 1 January 2020.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision)</num>
                        <content>
                            <p>
                                Notwithstanding any provisions of [
                                <i>the Agreement</i>
                                ], a benefit
        under [
                                <i>the Agreement</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
        Agreement</i>
                                ].
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <article eId="art_29">
                <num>Article 29</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 Agreement have been complied
      with.</p>
                    <p>2. The Agreement 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, on income derived on or after 1 January in
      the calendar year next following the year in which the Agreement enters into force;</p>
                    <p>b) in respect of other taxes on income, and taxes on capital, for taxes chargeable for
      any tax year beginning on or after 1 January in the calendar year next following the year in
      which the Agreement enters into force.</p>
                    <p>3. The Convention between the Republic of Finland and the State of Israel for the
      avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
      income and capital, signed at Jerusalem on 21 January 1965, as amended by the Exchange of
      Notes of 19 and 26 October 1970 (hereinafter referred to as "the 1965 Convention"), shall
      cease to have effect with respect to taxes to which this Agreement applies in accordance with
      the provisions of paragraph 2. The 1965 Convention shall terminate on the last date on which
      it has effect in accordance with the foregoing provision of this paragraph.</p>
                    <p>4. Article 20 of the 1965 Convention shall, notwithstanding the provisions of
      paragraphs 2 and 3, continue to be applied for the first three years next following the year
      for which the Agreement is effective in accordance with the aforementioned
      paragraphs.</p>
                </content>
            </article>
            <article eId="art_30">
                <num>Article 30</num>
                <heading>Termination</heading>
                <content>
                    <p>This Agreement shall remain in force until terminated by a Contracting State. Either
      Contracting State may terminate the Agreement, through diplomatic channels, by giving notice
      of termination at least six months before the end of any calendar year following after the
      period of five years from the date on which the Agreement enters into force. In such event,
      the Agreement shall cease to have effect in both Contracting States:</p>
                    <p>a) in respect of taxes withheld at source, on income derived on or after 1 January in
      the calendar year next following the year in which the notice is given;</p>
                    <p>b) in respect of other taxes on income, and taxes on capital, for taxes chargeable for
      any tax 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
      Agreement.</p>
                    <p>Done in duplicate at Helsinki this 8th day of January 1997, corresponding to the 29th
      day of Tevet 5757, in the English language.</p>
                </content>
            </article>
        </mainBody>
    </doc>
</akomaNtoso>
