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        <preface>
            <p>
                <docNumber>78-79/1992</docNumber>
                <docTitle>Convention between Finland and Barbados for the avoidance of double taxation with respect to taxes on income</docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN FINLAND AND BARBADOS FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME</heading>
                        <p>This document presents the synthesised text for the application of the Convention
      between Finland and Barbados for the avoidance of double taxation with respect to taxes on
      income signed on 15 June 1989 and the Protocol signed on 3 November 2011 (the “Convention”),
      as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent
      Base Erosion and Profit Shifting signed by Finland on 7 June 2017 and by Barbados on 24
      January 2018 (the “MLI”).</p>
                        <p>This document was prepared by the competent authority of Finland and represents its
      understanding of the modifications made to the Convention by the MLI.</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
      Barbados submitted to the Depositary upon ratification on 21 December 2020. 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. Whereas the Convention as presented in this synthesised text
      incorporates changes contained in the Protocol (signed on 3 November 2011) into the original
      1989 Convention for readability, the 1989 Convention and the Protocol (signed on 3 November
      2011) 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 Barbados 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 21 December 2020 for Barbados.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 April 2021
      for Barbados.</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 Barbados submitted to the
      Depositary upon ratification on 21 December 2020 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
      Barbados is published in the Treaty Series of the Statute Book of Finland SopS 19/2021. Link
      to Finnish language version
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2021/20210019/20210019_1">https://finlex.fi/fi/sopimukset/sopsteksti/2021/20210019/20210019_1</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2021/fds20210019.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2021/fds20210019.pdf</a>
                        </p>
                        <p>
                            Convention between Finland and Barbados for the avoidance of double taxation with
      respect to taxes on income signed on 15 June 1989 is published in the Treaty Series of the
      Statute Book of Finland SopS 79/1992. Link to Finnish language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1992/19920079">https://www.finlex.fi/fi/sopimukset/sopsteksti/1992/19920079</a>
                        </p>
                        <p>
                            Protocol amending the Convention Finland and Barbados for the avoidance of double
      taxation with respect to taxes on income signed on 3 November 2011 is published in the Treaty
      Series of the Statute Book of Finland SopS 58/2013. Link to Finnish language version
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2013/20130058">https://finlex.fi/fi/sopimukset/sopsteksti/2013/20130058</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2013/fds20130058.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2013/fds20130058.pdf</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Convention between Finland and Barbados for the avoidance of double taxation with respect to taxes on income</p>
            <p>The Government of Finland and the Government of Barbados,</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,]</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 paragraph 1 of Article 35 of the MLI, paragraph 1 of Article 6
          of the MLI has effect with respect to the application of the Convention by
          Barbados:</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 Barbados, for taxes levied with
          respect to taxable periods beginning on or after 1 October 2021.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 6 OF THE MLI – PURPOSE OF A COVERED TAX AGREEMENT</num>
                        <content>
                            <p>
                                Intending to eliminate double taxation with respect to the taxes covered by
          [
                                <i>this Convention</i>
                                ] without creating opportunities for non-taxation
        or reduced taxation through tax evasion or avoidance (including through treaty-shopping
        arrangements aimed at obtaining reliefs provided in [
                                <i>the Convention</i>
                                ]
        for the indirect benefit of residents of third jurisdictions),
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <p>Have agreed as follows:</p>
        </preamble>
        <mainBody>
            <article eId="art_1">
                <num>Article 1</num>
                <heading>Personal scope</heading>
                <content>
                    <p>This Convention shall apply to persons who are residents of one or both of the
      Contracting States.</p>
                </content>
            </article>
            <article eId="art_2">
                <num>Article 2</num>
                <heading>Taxes covered</heading>
                <content>
                    <p>1. The existing taxes to which this Convention shall apply are:</p>
                    <p>a) in Finland:</p>
                    <p>(i) the state income tax;</p>
                    <p>(ii) the communal tax;</p>
                    <p>(iii) the church tax; and</p>
                    <p>(iv) the tax withheld at source from non-residents' income;</p>
                    <p>(hereinafter referred to as "Finnish tax");</p>
                    <p>b) in Barbados:</p>
                    <p>(i) the income tax (including premium income tax);</p>
                    <p>(ii) the corporation tax (including tax on branch profits); and</p>
                    <p>(iii) the petroleum winning operations tax;</p>
                    <p>(hereinafter referred to as "Barbados tax").</p>
                    <p>2. The Convention shall apply also to any identical or substantially similar taxes
      which are imposed after the date of signature of the Convention in addition to, or in place
      of, the existing taxes. The competent authorities of the Contracting States shall notify each
      other of any significant changes which have been made in their respective taxation
      laws.</p>
                </content>
            </article>
            <article eId="art_3">
                <num>Article 3</num>
                <heading>General definitions</heading>
                <content>
                    <p>1. For the purposes of this Convention, unless the context otherwise
      requires:</p>
                    <p>a) the term "Finland" means the Republic of Finland and, when used in a geographical
      sense, means the territory of the Republic of Finland, and any area adjacent to the
      territorial waters of the Republic of Finland within which, under the laws of Finland and in
      accordance with international law, the rights of Finland with respect to the exploration for
      and exploitation of the natural resources of the sea bed and its sub-soil and of the
      superjacent waters may be exercised;</p>
                    <p>b) the term "Barbados" means the island of Barbados and the territorial waters
      thereof, including any area outside such territorial waters which in accordance with
      international law and the laws of Barbados is an area within which the rights of Barbados with
      respect to the sea bed and sub-soil and their natural resources 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 "national" means any individual possessing the nationality of a
      Contracting State, and any legal person, partnership and association deriving its status as
      such from the laws in force in a Contracting State;</p>
                    <p>g) the term "international traffic" means any transport by a ship or aircraft, except
      when such transport is solely between places within a Contracting State;</p>
                    <p>h) the term "competent authority" means:</p>
                    <p>(i) in Finland, the Ministry of Finance or its authorised representative;</p>
                    <p>(ii) in Barbados, the Minister of Finance or his authorised representative.</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 law of that State concerning the taxes to which the Convention applies.</p>
                </content>
            </article>
            <article eId="art_4">
                <num>Article 4</num>
                <heading>Residence</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. However,
      the term does not include any person who is liable to tax in that State in respect only of
      income from sources in that State.</p>
                    <p>2. Where by reason of the provisions of paragraph 1 an individual is a resident of
      both Contracting States, then his status shall be determined as follows:</p>
                    <p>a) he shall be deemed to be a resident of the State in which he has a permanent home
      available to him; if he has a permanent home available to him in both States, he shall be
      deemed to be a resident of the State with which his personal and economic relations are closer
      (centre of vital interests);</p>
                    <p>b) if the State in which he has his centre of vital interests cannot be determined, or
      if he has not a permanent home available to him in either State, he shall be deemed to be a
      resident of the State in which he has an habitual abode;</p>
                    <p>c) if 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, the competent authorities of the Contracting States
      shall settle the question by mutual agreement.</p>
                </content>
            </article>
            <article eId="art_5">
                <num>Article 5</num>
                <heading>Limitation of relief</heading>
                <content>
                    <p>Where under any provision of this Convention income or capital gains are relieved from
      Finnish tax and, under the law in force in Barbados, an individual in respect of the said
      income or capital gains is liable to tax by reference to the amount thereof which is remitted
      to or received in Barbados and not by reference to the full amount thereof, then the relief to
      be allowed under the Convention in Finland shall apply only to so much of the income or
      capital gains as are remitted to or received in Barbados.</p>
                </content>
            </article>
            <article eId="art_6">
                <num>Article 6</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;</p>
                    <p>f) a store or other sales outlet;</p>
                    <p>g) a mine, an oil or gas well, a quarry or any other place of extraction of natural
      resources; and</p>
                    <p>h) the maintenance of substantial equipment or machinery for a period of more than six
      months.</p>
                    <p>3. A building site, or construction, assembly or installation project or supervisory
      activities in connection therewith constitute a permanent establishment only if such site,
      project or activities last 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. However, when the activities of
      such an agent are devoted wholly or almost wholly on behalf of that enterprise, he will not be
      considered an agent of an independent status within the meaning of this paragraph but in such
      cases the provisions of paragraph 4 shall apply.</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_7">
                <num>Article 7</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 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_8">
                <num>Article 8</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. Notwithstanding the provisions of paragraph 1, where an enterprise of a Contracting
      State which has a permanent establishment in the other Contracting State carries on business
      activities in that other State otherwise than through the permanent establishment, of the same
      or similar kind as the business activities carried on by the permanent establishment, then the
      profits of such activities may be attributable to the permanent establishment unless the
      enterprise shows that such activities could not have been reasonably undertaken by the
      permanent establishment.</p>
                    <p>3. Subject to the provisions of paragraph 4, 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>4. 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>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. If the information available to the tax authority concerned is inadequate to
      determine the profits to be attributed to the permanent establishment, such profits may be
      determined by the exercise of discretion or the making of an estimate by that authority,
      provided that such discretion shall be exercised or such estimate shall be made in accordance
      with the principles stated in this Article.</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="art_9">
                <num>Article 9</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 in international traffic shall be taxable only in that State;</p>
                    <p>3. The provisions of paragraph 1 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_10">
                <num>Article 10</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 by the first-mentioned
      State claimed to be profits which would have accrued to the enterprise of the first-mentioned
      State if the conditions made between the two enterprises had been those which would have been
      made between independent enterprises, then that other State shall make an appropriate
      adjustment to the amount of tax charged therein on those profits, where that other State
      considers the adjustment justified. In determining such adjustment, due regard shall be had to
      the other provisions of this Convention and the competent authorities of the Contracting
      States shall if necessary consult each other.</p>
                </content>
            </article>
            <article eId="art_11">
                <num>Article 11</num>
                <heading>Dividends</heading>
                <content>
                    <p>1. Dividends paid by a company which is a resident of a Contracting State to a
      resident of the other Contracting State may be taxed in that other State.</p>
                    <p>2. However, such dividends may also be taxed in the Contracting State of which the
      company paying the dividends is a resident and according to the laws of that State, but if the
      recipient is the beneficial owner of the dividends 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 holds directly at least 10 per cent of the voting
      power of the company paying the dividends;</p>
                    <p>b) 15 per cent of the gross amount of the dividends in all other cases.</p>
                    <p>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. Notwithstanding the provisions of paragraph 2, dividends paid by a company which is
      a resident of Barbados to the Finnish Fund for Industrial Development Co-operation Ltd
      (Finnfund) shall be exempt from Barbados tax.</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 8 or Article 16, 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. Where a company which is a resident of a Contracting State derives profits or
      income from activities carried on by that company through a permanent establishment situated
      in the other Contracting State, then any profits or income remitted or deemed to have been
      remitted by the permanent establishment to the head office of the company or any other of its
      offices may, notwithstanding any other provisions of the Convention, be taxed in accordance
      with the law of the other Contracting State, but the tax so charged shall not exceed 5 per
      cent of the profits or income remitted or deemed to have been remitted.</p>
                </content>
            </article>
            <article eId="art_12">
                <num>Article 12</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 recipient is the beneficial owner
      of the interest the tax so charged shall not exceed 5 per cent of the gross amount of the
      interest.</p>
                    <p>3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting
      State and paid to the Government of the other Contracting State shall be exempt from tax in
      the first-mentioned State.</p>
                    <p>4. For the purposes of paragraph 3, the term "Government" means:</p>
                    <p>a) in the case of Finland,</p>
                    <p>(i) the Government of Finland;</p>
                    <p>(ii) the "Suomen Pankki" (the Central Bank of Finland);</p>
                    <p>(iii) the Finnish Fund for Industrial Development Co-operation Ltd
      (Finnfund);</p>
                    <p>(iv) the Finnish Export Credit Ltd; and</p>
                    <p>(v) any other like institution, as may be agreed upon from time to time between the
      Governments of the Contracting States;</p>
                    <p>b) in the case of Barbados,</p>
                    <p>(i) the Government of Barbados;</p>
                    <p>(ii) the Central Bank of Barbados;</p>
                    <p>(iii) the Barbados Development Bank; and</p>
                    <p>(iv) any other like institution, as may be agreed upon from time to time between the
      Governments of the Contracting States.</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. 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 and 2 shall not apply if the beneficial owner of the
      interest, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the interest arises, through a permanent establishment situated
      therein, or performs in that other State independent personal services from a fixed base
      situated therein, and the debt-claim in respect of which the interest is paid is effectively
      connected with:</p>
                    <p>a) such permanent establishment or fixed base, or</p>
                    <p>b) business activities referred to m paragraph 2 of Article 8.</p>
                    <p>In such cases the provisions of Article 8 or Article 16, as the case may be, shall
      apply.</p>
                    <p>7. Interest shall be deemed to arise in a Contracting State when the payer is that
      State itself, a local authority or a resident of the 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 Convention.</p>
                </content>
            </article>
            <article eId="art_13">
                <num>Article 13</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 recipient is the beneficial owner of
      the royalties, the tax so charged shall not exceed 5 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 cinematograph films, and films or tapes for radio or television
      broadcasting, any patent, trade mark, design or model, pian, secret formula or process, or for
      information concerning industrial, commercial or scientific experience.</p>
                    <p>4. Notwithstanding the provisions of paragraphs l and 2, copyright royalties in
      respect of the use of, or the right to use, any literary, artistic or scientific work
      (including royalties in respect of cinematograph films and films or tapes for radio or
      television broadcasting) arising in a Contracting State and paid to a resident of the other
      Contracting State shall be exempt from tax in the first-mentioned State.</p>
                    <p>5. The provisions of paragraphs 1, 2 and 4 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:</p>
                    <p>a) such permanent establishment or fixed base, or</p>
                    <p>b) business activities referred to m paragraph 2 of Article 8.</p>
                    <p>In such cases the provisions of Article 8 or Article 16, as the case may be, shall
      apply.</p>
                    <p>6. 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 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>7. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the royalties, having
      regard to the use, right or information for which they are paid, exceeds the amount which
      would have been agreed upon by the payer and the beneficial owner in the absence of such
      relationship, the provisions of this Article shall apply only to the last-mentioned amount. In
      such case, the excess part of the payments shall remain taxable according to the laws of each </p>
                    <p>Contracting State, due regard being had to the other provisions of this
      Convention.</p>
                </content>
            </article>
            <article eId="art_14">
                <num>Article 14</num>
                <heading>Management charges</heading>
                <content>
                    <p>1. Management charges paid by a resident of a Contracting State to an enterprise of
      the other Contracting State may be taxed in that other State.</p>
                    <p>2. However, such management charges may also be taxed in the Contracting State of
      which the person paying the management charges is a resident and according to the laws of that
      State, but the tax so charged shall not exceed 5 per cent of the gross amount of the
      charges.</p>
                    <p>3. The term "management charges" as used in this Article means payments of any kind to
      an enterprise for, or in respect of, the provision of industrial or commercial advice, or
      management or technical services, or similar services or facilities, but it does not include
      payments for independent persona) services mentioned in Article 16.</p>
                    <p>4. The provisions of paragraphs 1 and 2 shall not apply if the enterprise to which the
      management charges are paid, being an enterprise of a Contracting State, carries on business
      in the other Contracting State from which the management charges are paid, through a permanent
      establishment situated therein and the services for which the management charges are paid are
      effectively connected with:</p>
                    <p>a) such permanent establishment, or</p>
                    <p>b) business activities referred to in paragraph 2 of Article 8.</p>
                    <p>In such cases the provisions of Article 8 shall apply.</p>
                    <p>5. 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 management charges, having
      regard to the services 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="art_15">
                <num>Article 15</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 7 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 7 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 derived by a resident of a Contracting State from the alienation of ships,
      aircraft or containers (including trailers, barges and related equipment for the transport of
      containers) 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>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="art_16">
                <num>Article 16</num>
                <heading>Independent personal services</heading>
                <content>
                    <p>1. Income derived by an individual who is 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 or he is present in that other State for a
      period or periods exceeding in the aggregate 90 days in any twelve-month period. If he has
      such a fixed base or remains in that other State for the aforesaid period or periods, the
      income may be taxed in the other State but only so much of it as is attributable to that fixed
      base or is derived from his activities performed in that other State during the aforesaid
      period or periods.</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_17">
                <num>Article 17</num>
                <heading>Dependent personal services</heading>
                <content>
                    <p>1. Subject to the provisions of Articles 18, 20, 21 and 22, 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</p>
                    <p>for a period or periods not exceeding in the aggregate 183 days within any
      twelve-month period, 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 a resident of a Contracting State, may be taxed in that State.</p>
                </content>
            </article>
            <article eId="art_18">
                <num>Article 18</num>
                <heading>Directors' fees and remuneration of top-level managerial officials</heading>
                <content>
                    <p>1. 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>
                    <p>2. Salaries, wages and other similar remuneration derived by a resident of a
      Contracting State in his capacity as an official in a top-level managerial position 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_19">
                <num>Article 19</num>
                <heading>Artistes and sportsmen</heading>
                <content>
                    <p>1. Notwithstanding the provisions of Articles 16 and 17, 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 8, 16 and 17, be
      taxed in the Contracting State in which the activities of the entertainer or sportsman are
      exercised.</p>
                    <p>3. Notwithstanding the provisions of paragraphs 1 and 2, income derived in respect of
      activities referred to in paragraph 1 shall be exempt from tax in the Contracting State in
      which the activities are exercised, if</p>
                    <p>a) the visit of the entertainer or sportsman to that State is substantially supported
      by public funds of the other Contracting State or a statutory body or local authority
      thereof;</p>
                    <p>b) the income is derived by a non-profit organisation, no part of the income of which
      was payable to, or was otherwise available for, the personal benefit of any proprietor, member
      or shareholder thereof; or </p>
                    <p>c) the income of the entertainer or sportsman is derived in respect of services
      provided to an organisation referred to in sub-paragraph b).</p>
                </content>
            </article>
            <article eId="art_20">
                <num>Article 20</num>
                <heading>Pensions</heading>
                <content>
                    <p>Subject to the provisions of paragraph 2 of Article 21, pensions, including payments
      made under the social security legislation, derived from sources within a Contracting State
      may be taxed in that State.</p>
                </content>
            </article>
            <article eId="art_21">
                <num>Article 21</num>
                <heading>Government service</heading>
                <content>
                    <p>1. a) 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 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 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>3. The provisions of Articles 17, 18 and 20 shall apply to remuneration and 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_22">
                <num>Article 22</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 full time education or training, whether at undergraduate or postgraduate level,
      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 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>
                    <p>3. Where the remuneration referred to in paragraph 2 is in excess of the amount which
      constitutes earnings necessary for the maintenance of the student or apprentice, the excess
      part of the remuneration shall remain taxable according to the laws of each Contracting State,
      due regard being had to the other provisions of this Convention.</p>
                </content>
            </article>
            <article eId="art_23">
                <num>Article 23</num>
                <heading>Offshore activities</heading>
                <content>
                    <p>1. The provisions of this Article shall apply notwithstanding any other provision of
      this Convention.</p>
                    <p>2. A person who is a resident of a Contracting State and carries on activities
      offshore in the other Contracting State in connection with the exploration or exploitation of
      the sea bed and sub-soil and their natural resources situated in that other State shall,
      subject to paragraphs 3 and 4, be deemed in relation to these activities to be carrying on
      business in that other State through a permanent establishment or fixed base situated
      therein.</p>
                    <p>3. The provisions of paragraph 2 shall not apply where the activities are carried on
      for a period not exceeding 30 days in the aggregate in any twelve-month period. However, for
      the purposes of this paragraph:</p>
                    <p>a) activities carried on by an enterprise associated with another enterprise shall be
      regarded as carried on by the enterprise with which it is associated if the activities in
      question are substantially the same as those carried on by the last-mentioned
      enterprise;</p>
                    <p>b) two enterprises shall be deemed to be associated if one is controlled directly or
      indirectly by the other, or both are controlled directly or indirectly by a third person or
      persons.</p>
                    <p>4. Profits derived by an enterprise of a Contracting State from the transportation of
      supplies or personnel to a location, or between locations, where activities in connection with
      the exploration or exploitation of the sea bed and sub-soil and their natural resources are
      being carried on in a Contracting State, or from the operation of tugboats and other vessels
      auxiliary to such activities, shall be taxable only in the Contracting State in which the
      place of effective management of the enterprise is situated.</p>
                    <p>5. a) Subject to sub-paragraph b) salaries, wages and similar remuneration derived by
      a resident of a Contracting State in respect of an employment connected with the exploration
      or exploitation of the sea bed and sub-soil and their natural resources situated in the other
      Contracting State may, to the extent that the duties are performed offshore in that other
      State, be taxed in that other State provided that the employment offshore is carried on for a
      period exceeding 30 days in the aggregate in any twelve-month period.</p>
                    <p>b) Salaries, wages and similar remuneration derived by a resident of a Contracting
      State in respect of an employment exercised aboard a ship or aircraft engaged in the
      transportation of supplies or personnel to a location, or between locations, where activities
      connected with the exploration or exploitation of the sea bed and sub-soil and their natural
      resources are being carried on in a Contracting State, or in respect of an employment
      exercised aboard tugboats or other vessels operated auxiliary to such activities, shall be
      taxable only in the Contracting State in which the place of effective management of the
      enterprise is situated.</p>
                    <p>6. Gains derived by a resident of a Contracting State from the alienation
      of:</p>
                    <p>a) exploration or exploitation rights; or</p>
                    <p>b) property situated in the other Contracting State and used in connection with the
      exploration or exploitation of the sea bed and sub-soil and their natural resources situated
      in that other State; or</p>
                    <p>c) shares deriving their value or the greater part of their value directly or
      indirectly from such rights or such property or from such rights and such property taken
      together;</p>
                    <p>may be taxed in that other State.</p>
                    <p>In this paragraph "exploration or exploitation rights" mean rights to assets to be
      produced by the exploration or exploitation of the sea bed and sub-soil and their natural
      resources in the other Contracting State, including rights to interests in or to the benefit
      of such assets.</p>
                </content>
            </article>
            <article eId="art_24">
                <num>Article 24</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.
      However, any items of income of a resident of a Contracting State arising in the other
      Contracting State may also be taxed in that other 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 7, 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 8 or Article 16, as the case may be,
      shall apply.</p>
                </content>
            </article>
            <article eId="art_25">
                <num>Article 25</num>
                <heading>Elimination of double taxation</heading>
                <content>
                    <p>1. In Finland double taxation shall be eliminated as follows:</p>
                    <p>a) Where a resident of Finland derives income which, in accordance with the provisions
      of this Convention, may be taxed in Barbados, Finland shall, subject to the provisions of
      sub-paragraph b), allow as a deduction from the tax on income of that person, an amount equal
      to the tax on income paid in Barbados.</p>
                    <p>Such deduction shall not, however, exceed that part of the tax on income, as computed
      before the deduction is given, which is attributable to the income which may be taxed in
      Barbados.</p>
                    <p>b) Dividends paid by a company which is a resident of Barbados to a company which is a
      resident of Finland and controls directly at least 10 percent of the voting power of the
      company paying the dividends shall be exempt from Finnish tax.</p>
                    <p>c) Notwithstanding any other provision of this Convention, an individual who is a
      resident of Barbados and under Finnish taxation law with respect to the Finnish taxes referred
      to in Article 2 also is regarded as a resident of Finland may be taxed in Finland. However,
      Finland shall allow any Barbados tax paid on the income as a deduction from Finnish tax in
      accordance with the provisions of sub-paragraph a). The provisions of this sub-paragraph shall
      apply only to nationals of Finland.</p>
                    <p>d) Where in accordance with any provisions of the Convention income derived by a
      resident of Finland is exempt from tax in Finland, Finland may nevertheless, in calculating
      the amount of tax on the remaining income of such resident, take into account the exempted
      income.</p>
                    <p>e) Where, however, a company which is a resident of Finland derives interest,
      royalties or management charges which in accordance with Article 12, 13 or 14 may be taxed in
      Barbados, Finland shall allow as a deduction from the tax on the interest, royalties or
      management charges an amount equal to 10 per cent of the gross amount of such interest,
      royalties or management charges.</p>
                    <p>f) For the purposes of sub-paragraph a) the term "tax on income paid in Barbados"
      shall include any amount which would have been payable as Barbados tax for any year by a
      resident of Finland on profits attributable to a business carried on in Barbados, but for an
      exemption from, or a reduction of, tax granted for that year or any part thereof under the
      Hotel Aids Act, Cap. 72 and the Fiscal Incentives Act, Cap. 71A or any other legislation which
      may subsequently be enacted, granting an exemption or reduction which is agreed by the
      competent authorities of the Contracting States to be of a substantially similar character, if
      it has not been modified thereafter or has been modified only in minor respects so as not to
      affect its general character.</p>
                    <p>g) The provisions of sub-paragraph f) shall apply for the first ten years for which
      the Convention is effective, but the competent authorities of the Contracting States may
      consult each other to determine whether this period shall be extended.</p>
                    <p>2. In Barbados double taxation shall be eliminated as follows:</p>
                    <p>a) Subject to the provisions of the laws of Barbados regarding the allowance as a
      credit against Barbados tax of tax payable in a territory outside Barbados (which shall not
      affect the general principle hereof):</p>
                    <p>(i) Finnish tax payable under the laws of Finland and in accordance with the
      Convention, whether directly or by deduction, on profits or income from sources within Finland
      (excluding, in the case of a dividend, tax payable in respect of the profits out of which the
      dividend is paid) shall be allowed as a credit against any Barbados tax computed by reference
      to the same profits or income by reference to which the Finnish tax is computed;</p>
                    <p>(ii) in the case of a dividend paid by a company which is a resident of Finland to a
      company which is a resident of Barbados and which controls directly or indirectly at least l0
      per cent of the voting power in the company paying the dividend, the credit shall take into
      account (in addition to any Finnish tax creditable under sub-paragraph a) (i)) the Finnish tax
      payable by the company paying the dividend in respect of the profits out of which such
      dividend is paid.</p>
                    <p>b) The credit, however, shall in no case exceed that part of the tax as computed
      before the credit is given, which is appropriate to the income which may be taxed in
      Finland.</p>
                </content>
            </article>
            <article eId="art_26">
                <num>Article 26</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.</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 persona) 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 10, paragraph 8 of Article
      12, paragraph 7 of Article 13, or paragraph 5 of Article 14, apply, interest, royalties,
      management charges 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.</p>
                    <p>4. The provisions of paragraph 2 shall not be construed so as to prevent Barbados from
      applying its tax on branch profits, and its tax on the premium income of non-resident insurers
      or foreign insurance companies at the rates specified under the Income Tax Act.</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. In this Article the term "taxation" means taxes to which this Convention
      applies.</p>
                </content>
            </article>
            <article eId="art_27">
                <num>Article 27</num>
                <heading>Limitation of benefits</heading>
                <content>
                    <p>1. A resident of a Contracting State deriving income or profits from the other
      Contracting State shall not be entitled in that other State to the benefits of Articles 7 to
      25 if 50 per cent or less of the beneficial interest in such person (or in the case of a
      company, 50 per cent or less of the number of shares of each class of the company's shares) is
      owned, directly or indirectly, by any combination of one or more individual residents of a
      Contracting State.</p>
                    <p>2. 2. The provisions of paragraph 1 shall not apply if the income or profits derived in a
      Contracting State is derived from trading or service activities under the International
      Business Companies Act, Cap. 77 or the Societies with Restricted Liability Act, 318B or
      nonbanking activities under the International Financial Services Act, Cap. 325, or any other
      provision which may be enacted after the date of signature of this Convention and which the
      competent authorities of the Contracting States agree to be of a substantially similar
      character. A person engaged in the business of banking under the International Financial
      Services Act, Cap. 325 or insurance under the Exempt Insurance Act, Cap. 308A or carrying on
      the business of an investment company under the International Business Companies Act, Cap. 77
      or the Societies with Restricted Liability Act, 318B or any other provision which may be
      enacted after the date of signature of the Convention and which the competent authorities of
      the Contracting States agree to be of a substantially similar character, shall be excluded
      from the benefits of Articles 7 to 25. (SopS 57–58/2013)</p>
                    <p>3. The provisions of paragraph 1 shall not apply if the person deriving the income is
      a company which is a resident of a Contracting State in whose principal class of shares there
      is a substantial and regular trading on a recognised stock exchange.</p>
                    <p>4. If a Contracting State proposes to deny benefits to a resident of the other
      Contracting State by reason of this Article, the competent authorities of the Contracting
      States shall consult each other.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_1" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1992/79#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_28">
                <num>Article 28</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 26, 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 28 of this Convention:
                                        <authorialNote marker="2" 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 paragraph 1 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 Barbados:</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 Barbados, for taxes levied with
            respect to taxable periods beginning on or after 1 October 2021.</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 [C
                                        <i>ontracting 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. In the event
      the competent authorities reach an agreement, taxes shall be imposed, and refund or credit of
      taxes shall be allowed by the Contracting States in accordance with such agreement. It 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. In particular, the competent authorities of the Contracting States may
      agree:</p>
                    <p>a) to the same attribution of income, deductions, credits, or allowances of an
      enterprise of a Contracting State to its permanent establishment situated in the other
      Contracting State;</p>
                    <p>b) to the same allocation of income, deductions, credits, or allowances between
      persons;</p>
                    <p>c) to the same characterisation of particular items of income;</p>
                    <p>d) to the same application of source rules with respect to particular items of
      income;</p>
                    <p>e) to a common meaning of a term;</p>
                    <p>f) to increases in any specific amounts referred to in the Convention to reflect
      economic or monetary developments; and</p>
                    <p>g) to the application of the provisions of domestic law regarding interest on
      deficiencies and refunds and non-criminal penalties and fines, in a manner consistent with the
      purposes of the Convention.</p>
                    <p>They may also consult together for the elimination of double taxation in cases not
      provided for in the Convention.</p>
                    <p>4. The competent authorities of the Contracting States may communicate with each other
      directly for the purpose of reaching an agreement in the sense of the preceding
      paragraphs.</p>
                </content>
            </article>
            <p>
                <embeddedStructure class="mli-addition">
                    <p>
                        <authorialNote>
                            <p>
                                The following Part VI of the MLI applies to this Convention:
                                <authorialNote marker="3" placement="bottom">
                                    <p>In accordance with paragraph 1 of Article 36 of the MLI, the provisions of Part VI
          (Arbitration) of the MLI has effect with respect to this Convention:  </p>
                                    <p>a) with respect to cases presented to the competent authority of a Contracting
          State on or after 1 April 2021; and </p>
                                    <p>b) with respect to cases presented to the competent authority of a Contracting
          State prior to 1 April 2021, on the date when both Contracting States have notified the
          Secretary-General of the OECD that they have reached mutual agreement pursuant to
          paragraph 10 of Article 19 of the MLI (Mandatory Binding Arbitration), along with
          information regarding the date or dates on which such cases shall be considered to have
          been presented to the competent authority of a Contracting State (as described in
          subparagraph a) of paragraph 1 of Article 19 of the MLI (Mandatory Binding Arbitration))
          according to the terms of that mutual agreement.</p>
                                    <p>However, the scope of cases eligible for arbitration under the provisions of Part
          VI of the MLI is limited due to reservations formulated in accordance with subparagraph a)
          of paragraph 2 of Article 28 of the MLI by the Contracting States. See these reservations
          at the end of this box.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <chapter>
                        <num>PART VI. ARBITRATION</num>
                        <article>
                            <num>Article 19 (Mandatory Binding Arbitration) of the MLI</num>
                            <content>
                                <p>1. Where:</p>
                                <p>
                                    a) under [
                                    <i>paragraph 1 of Article 28 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 28 of the Convention</i>
                                    ], within a
          period of two years beginning on the start date referred to in paragraph 8 or 9
            [
                                    <i>of Article 19 of the MLI</i>
                                    ], as the case may be (unless, prior to
          the expiration of that period the competent authorities of the [
                                    <i>Contracting
            States</i>
                                    ] have agreed to a different time period with respect to that case and
          have notified the person who presented the case of such agreement),
                                </p>
                                <p>
                                    any unresolved issues arising from the case shall, if the person so requests in
          writing, be submitted to arbitration in the manner described in [
                                    <i>Part VI of the
            MLI</i>
                                    ], according to any rules or procedures agreed upon by the competent
          authorities of the [
                                    <i>Contracting States</i>
                                    ] pursuant to the provisions
          of paragraph 10 [
                                    <i>of Article 19 of the MLI</i>
                                    ].
                                </p>
                                <p>
                                    2. Where a competent authority has suspended the mutual agreement procedure
          referred to in paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ] because a
          case with respect to one or more of the same issues is pending before court or
          administrative tribunal, the period provided in subparagraph b) of paragraph 1
            [
                                    <i>of Article 19 of the MLI</i>
                                    ] will stop running until either a final
          decision has been rendered by the court or administrative tribunal or the case has been
          suspended or withdrawn. In addition, where a person who presented a case and a competent
          authority have agreed to suspend the mutual agreement procedure, the period provided in
          subparagraph b) of paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ] will stop
          running until the suspension has been lifted.
                                </p>
                                <p>
                                    3. Where both competent authorities agree that a person directly affected by the
          case has failed to provide in a timely manner any additional material information
          requested by either competent authority after the start of the period provided in
          subparagraph b) of paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ], the
          period provided in subparagraph b) of paragraph 1 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ] shall be extended for an amount of time equal to the period beginning
          on the date by which the information was requested and ending on the date on which that
          information was provided.
                                </p>
                                <p>
                                    4. a) The arbitration decision with respect to the issues submitted to arbitration
          shall be implemented through the mutual agreement concerning the case referred to in
          paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ]. The arbitration decision
          shall be final.
                                </p>
                                <p>
                                    b) The arbitration decision shall be binding on both [
                                    <i>Contracting
            States</i>
                                    ] except in the following cases:
                                </p>
                                <p>i) if a person directly affected by the case does not accept the mutual agreement
          that implements the arbitration decision. In such a case, the case shall not be eligible
          for any further consideration by the competent authorities. The mutual agreement that
          implements the arbitration decision on the case shall be considered not to be accepted by
          a person directly affected by the case if any person directly affected by the case does
          not, within 60 days after the date on which notification of the mutual agreement is sent
          to the person, withdraw all issues resolved in the mutual agreement implementing the
          arbitration decision from consideration by any court or administrative tribunal or
          otherwise terminate any pending court or administrative proceedings with respect to such
          issues in a manner consistent with that mutual agreement.</p>
                                <p>
                                    ii) if a final decision of the courts of one of the [
                                    <i>Contracting
            States</i>
                                    ] holds that the arbitration decision is invalid. In such a case, the
          request for arbitration under paragraph 1 [
                                    <i>of Article 19 of the
          MLI</i>
                                    ] shall be considered not to have been made, and the arbitration process
          shall be considered not to have taken place (except for the purposes of Articles 21
          (Confidentiality of Arbitration Proceedings) and 25 (Costs of Arbitration Proceedings)
            [
                                    <i>of the MLI</i>
                                    ]). In such a case, a new request for arbitration may
          be made unless the competent authorities agree that such a new request should not be
          permitted.
                                </p>
                                <p>iii) if a person directly affected by the case pursues litigation on the issues
          which were resolved in the mutual agreement implementing the arbitration decision in any
          court or administrative tribunal.</p>
                                <p>
                                    5. The competent authority that received the initial request for a mutual
          agreement procedure as described in subparagraph a) of paragraph 1 [
                                    <i>of Article
            19 of the MLI</i>
                                    ] shall, within two calendar months of receiving the
          request:
                                </p>
                                <p>a) send a notification to the person who presented the case that it has received
          the request; and</p>
                                <p>
                                    b) send a notification of that request, along with a copy of the request, to the
          competent authority of the other [
                                    <i>Contracting State</i>
                                    ].
                                </p>
                                <p>
                                    6. Within three calendar months after a competent authority receives the request
          for a mutual agreement procedure (or a copy thereof from the competent authority of the
          other [
                                    <i>Contracting State</i>
                                    ]) it shall either:
                                </p>
                                <p>a) notify the person who has presented the case and the other competent authority
          that it has received the information necessary to undertake substantive consideration of
          the case; or</p>
                                <p>b) request additional information from that person for that purpose.</p>
                                <p>
                                    7. Where pursuant to subparagraph b) of paragraph 6 [
                                    <i>of Article 19 of
            the MLI</i>
                                    ], one or both of the competent authorities have requested from the
          person who presented the case additional information necessary to undertake substantive
          consideration of the case, the competent authority that requested the additional
          information shall, within three calendar months of receiving the additional information
          from that person, notify that person and the other competent authority either:
                                </p>
                                <p>a) that it has received the requested information; or</p>
                                <p>b) that some of the requested information is still missing.</p>
                                <p>
                                    8. Where neither competent authority has requested additional information pursuant
          to subparagraph b) of paragraph 6 [
                                    <i>of Article 19 of the MLI</i>
                                    ], the
          start date referred to in paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ]
          shall be the earlier of:
                                </p>
                                <p>
                                    a) the date on which both competent authorities have notified the person who
          presented the case pursuant to subparagraph a) of paragraph 6 [
                                    <i>of Article 19 of
            the MLI</i>
                                    ]; and
                                </p>
                                <p>
                                    b) the date that is three calendar months after the notification to the competent
          authority of the other [
                                    <i>Contracting State</i>
                                    ] pursuant to subparagraph
          b) of paragraph 5 [
                                    <i>of Article 19 of the MLI</i>
                                    ].
                                </p>
                                <p>
                                    9. Where additional information has been requested pursuant to subparagraph b) of
          paragraph 6 [
                                    <i>of Article 19 of the MLI</i>
                                    ], the start date referred to
          in paragraph 1 [
                                    <i>of Article 19 of the MLI</i>
                                    ] shall be the earlier
          of:
                                </p>
                                <p>
                                    a) the latest date on which the competent authorities that requested additional
          information have notified the person who presented the case and the other competent
          authority pursuant to subparagraph a) of paragraph 7 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ]; and
                                </p>
                                <p>b) the date that is three calendar months after both competent authorities have
          received all information requested by either competent authority from the person who
          presented the case.</p>
                                <p>
                                    If, however, one or both of the competent authorities send the notification
          referred to in subparagraph b) of paragraph 7 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ], such notification shall be treated as a request for additional
          information under subparagraph b) of paragraph 6 [
                                    <i>of Article 19 of the
            MLI</i>
                                    ].
                                </p>
                                <p>
                                    10. The competent authorities of the [
                                    <i>Contracting States</i>
                                    ]
          shall by mutual agreement pursuant to [
                                    <i>Article 28 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>
                            </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 the [
                                    <i>the Convention</i>
                                    ] related to
          exchange of information and administrative assistance and under the applicable laws of the
            [
                                    <i>Contracting States</i>
                                    ].
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 22 (Resolution of a Case Prior to the Conclusion of the Arbitration) of the MLI</num>
                            <content>
                                <p>
                                    For the purposes of [
                                    <i>Part VI of the MLI</i>
                                    ] and the provisions
          of [
                                    <i>the Convention</i>
                                    ] that provide for resolution of cases through
          mutual agreement, the mutual agreement procedure, as well as the arbitration proceeding,
          with respect to a case shall terminate if, at any time after a request for arbitration has
          been made and before the arbitration panel has delivered its decision to the competent
          authorities of the [
                                    <i>Contracting States</i>
                                    ]:
                                </p>
                                <p>
                                    a) the competent authorities of the [
                                    <i>Contracting States</i>
                                    ]
          reach a mutual agreement to resolve the case; or
                                </p>
                                <p>b) the person who presented the case withdraws the request for arbitration or the
          request for a mutual agreement procedure.</p>
                            </content>
                        </article>
                        <article>
                            <num>Article 23 (Type of Arbitration Process) of the MLI</num>
                            <content>
                                <p>
                                    1. Except to the extent that the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ] mutually agree on different rules, the
          following rules shall apply with respect to an arbitration proceeding pursuant to
            [
                                    <i>Part VI of the MLI</i>
                                    ]:
                                </p>
                                <p>
                                    a) After a case is submitted to arbitration, the competent authority of each
            [
                                    <i>Contracting State</i>
                                    ] shall submit to the arbitration panel, by a
          date set by agreement, a proposed resolution which addresses all unresolved issue(s) in
          the case (taking into account all agreements previously reached in that case between the
          competent authorities of the [
                                    <i>Contracting States</i>
                                    ]). The proposed
          resolution shall be limited to a disposition of specific monetary amounts (for example, of
          income or expense) or, where specified, the maximum rate of tax charged pursuant to
            [
                                    <i>the Convention</i>
                                    ], for each adjustment or similar issue in the
          case. In a case in which the competent authorities of the [
                                    <i>Contracting
            States</i>
                                    ] have been unable to reach agreement on an issue regarding the
          conditions for application of a provision of [
                                    <i>the Convention</i>
                                    ]
          (hereinafter referred to as a “threshold question”), such as whether an individual is a
          resident or whether a permanent establishment exists, the competent authorities may submit
          alternative proposed resolutions with respect to issues the determination of which is
          contingent on resolution of such threshold questions.
                                </p>
                                <p>
                                    b) The competent authority of each [
                                    <i>Contracting State</i>
                                    ] may
          also submit a supporting position paper for consideration by the arbitration panel. Each
          competent authority that submits a proposed resolution or supporting position paper shall
          provide a copy to the other competent authority by the date on which the proposed
          resolution and supporting position paper were due. Each competent authority may also
          submit to the arbitration panel, by a date set by agreement, a reply submission with
          respect to the proposed resolution and supporting position paper submitted by the other
          competent authority. A copy of any reply submission shall be provided to the other
          competent authority by the date on which the reply submission was due.
                                </p>
                                <p>
                                    c) The arbitration panel shall select as its decision one of the proposed
          resolutions for the case submitted by the competent authorities with respect to each issue
          and any threshold questions, and shall not include a rationale or any other explanation of
          the decision. The arbitration decision will be adopted by a simple majority of the panel
          members. The arbitration panel shall deliver its decision in writing to the competent
          authorities of the [
                                    <i>Contracting States</i>
                                    ]. The arbitration decision
          shall have no precedential value.
                                </p>
                                <p>
                                    5. Prior to the beginning of arbitration proceedings, the competent authorities of
          the [
                                    <i>Contracting States</i>
                                    ] shall ensure that each person that
          presented the case and their advisors agree in writing not to disclose to any other person
          any information received during the course of the arbitration proceedings from either
          competent authority or the arbitration panel. The mutual agreement procedure under
            [
                                    <i>the Convention</i>
                                    ], as well as the arbitration proceeding under
            [
                                    <i>Part VI of the MLI</i>
                                    ], with respect to the case shall terminate
          if, at any time after a request for arbitration has been made and before the arbitration
          panel has delivered its decision to the competent authorities of the
            [
                                    <i>Contracting States</i>
                                    ], a person that presented the case or one of
          that person’s advisors materially breaches that agreement.
                                </p>
                            </content>
                        </article>
                        <article>
                            <num>Article 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 [ ] where there is no double
          taxation. Double taxation means that both [
                                    <i>Contracting States</i>
                                    ] have
          imposed taxes in respect of the same taxable income [ ] giving rise to either additional
          tax charge, increase in tax liabilities or cancellation or reduction of losses, which
          could be used to offset taxable profits.
                                </p>
                                <p>
                                    4. Finland reserves the right to exclude from the scope of [
                                    <i>Part VI of
            the MLI</i>
                                    ]:
                                </p>
                                <p>a) with respect to taxes withheld at source on amounts paid or credited to
          non-residents, cases which concern taxable events giving rise to such taxes that occur
          before the reference date;</p>
                                <p>b) with respect to all other taxes, cases which concern taxes levied with respect
          to taxable periods that begin before the reference date.</p>
                                <p>For the purposes of this reservation, “the reference date” is the latest
          of:</p>
                                <p>
                                    i) the date of entry into effect of [
                                    <i>the MLI</i>
                                    ] in both
            [
                                    <i>Contracting States</i>
                                    ] with respect to such taxes;
                                </p>
                                <p>
                                    ii) the first day of January of the calendar year next following the expiration of
          a period of six calendar months beginning on the date of the communication by the
          Depositary of the latest definitive reservation withdrawal or notification which results
          in the application of [
                                    <i>Part VI of the MLI</i>
                                    ] between both
            [
                                    <i>Contracting States</i>
                                    ]; and
                                </p>
                                <p>
                                    iii) where the case is a type of case that would be potentially eligible for
          arbitration as a result of the withdrawal, subsequent to the entry into effect of
            [
                                    <i>Part VI of the MLI</i>
                                    ] as between both [
                                    <i>Contracting
            States</i>
                                    ], of [
                                    <i>Contracting State</i>
                                    ’s] 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>
                            </content>
                        </article>
                    </chapter>
                </embeddedStructure>
            </p>
            <article eId="art_29">
                <num>Article 29 (SopS 57–58/2013)</num>
                <heading>Exchange of information</heading>
                <content>
                    <p>1. The competent authorities of the Contracting States shall exchange such information
      as is foreseeably relevant for carrying out the provisions of this Convention or to the
      administration or enforcement of the domestic laws concerning taxes of every kind and
      description imposed on behalf of the Contracting States, or of their political subdivisions or
      local authorities, insofar as the taxation thereunder is not contrary to the Convention. The
      exchange of information is not restricted by Articles 1 or 2.</p>
                    <p>2. Any information received under paragraph 1 by a Contracting State shall be treated
      as confidential in the same manner as information obtained under the domestic laws of that
      Contracting State and shall be disclosed only to persons or authorities (including courts and
      administrative bodies) concerned with the assessment or collection of, the enforcement or
      prosecution in respect of, the determination of appeals in relation to the taxes referred to
      in paragraph 1, or the oversight of the above. Such persons or authorities shall use the
      information only for such purposes. They may disclose the information in public court
      proceedings or in judicial decisions. Notwithstanding the foregoing, information received by a
      Contracting State may be used for other purposes where this is permitted under the laws of
      both Contracting States and the competent authority of the requested Contracting State
      authorises such use.</p>
                    <p>3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose
      on a Contracting State the obligation:</p>
                    <p>a) to carry out administrative measures at variance with the laws and administrative
      practice of that or of the other Contracting State;</p>
                    <p>b) to supply information which is not obtainable under the laws or in the normal
      course of the administration of that or of the other Contracting State;</p>
                    <p>c) to supply information which would disclose any trade, business, industrial,
      commercial or professional secret or trade process, or information, the disclosure of which
      would be contrary to public policy (ordre public).</p>
                    <p>4. If information is requested by a Contracting State in accordance with this Article,
      the other Contracting State shall use its information gathering measures to obtain the
      requested information even though that other Contracting State may not need such information
      for its own tax purposes. The obligation contained in the preceding sentence is subject to the
      limitations of paragraph 3, but in no case shall such limitations be construed to permit a
      Contracting State to decline to supply information solely because it has no domestic interest
      in such information.</p>
                    <p>5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting
      State to decline to supply information solely because the information is held by a bank, other
      financial institution, nominee or person acting in an agency or a fiduciary capacity or
      because it relates to ownership interests in a person.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_2" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1992/79#protocol">Protocol</a>
                          to this Convention. 
                </p>
            </tblock>
            <article eId="art_30">
                <num>Article 30</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>
            <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="4" placement="bottom">
                                    <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
          Article 7 of the MLI has effect with respect to the application of this Convention by the
          Republic of Finland:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 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 paragraph 1 of Article 35 of the MLI, paragraph 1 of Article 7
          of the MLI has effect with respect to the application of the Convention by
          Barbados:</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 Barbados, for taxes levied with
          respect to taxable periods beginning on or after 1 October 2021.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision)</num>
                        <content>
                            <p>
                                Notwithstanding any provisions of [
                                <i>the Convention</i>
                                ], a benefit
        under [
                                <i>the Convention</i>
                                ] shall not be granted in respect of an item of
        income [ ] if it is reasonable to conclude, having regard to all relevant facts and
        circumstances, that obtaining that benefit was one of the principal purposes of any
        arrangement or transaction that resulted directly or indirectly in that benefit, unless it
        is established that granting that benefit in these circumstances would be in accordance with
        the object and purpose of the relevant provisions of [
                                <i>the
        Convention</i>
                                ].
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <article eId="art_31">
                <num>Article 31</num>
                <heading>Entry into force</heading>
                <content>
                    <p>1. The Governments of the Contracting States shall notify each other that the
      constitutional requirements for the entry into force of this Convention have been complied
      with.</p>
                    <p>2. The Convention shall enter into force thirty days after the date of the later of
      the notifications referred to in paragraph 1 and its provisions shall have effect:</p>
                    <p>a) in Finland:</p>
                    <p>(i) in respect of taxes withheld at source, on income derived on or after the first
      day of January in the calendar year next following the year in which the Convention enters
      into force;</p>
                    <p>(ii) in respect of other taxes on income, for taxes chargeable for any tax year
      beginning on or after the first day of January in the calendar year next following the year in
      which the Convention enters into force;</p>
                    <p>b) in Barbados:</p>
                    <p>(i) in respect of taxes withheld at source on amounts paid or remitted to
      non-residents on or after the first day of January in the calendar year next following that in
      which the Convention enters into force;</p>
                    <p>(ii) in respect of other taxes on income derived on or after the first day of January
      in the calendar year next following that in which the Convention enters into force.</p>
                </content>
            </article>
            <article eId="art_32">
                <num>Article 32</num>
                <heading>Termination</heading>
                <content>
                    <p>This Convention shall remain in force until terminated by a Contracting State. Either
      Contracting State may terminate the Convention, through diplomatic channels, by giving notice
      of termination at least six months before the end of any calendar year following after the
      period of five years from the date on which the Convention enters into force. In such event,
      the Convention shall cease to have effect:</p>
                    <p>a) in Finland:</p>
                    <p>(i) in respect of taxes withheld at source, on income derived on or after the first
      day of January in the calendar year next following the year in which the notice is
      given;</p>
                    <p>(ii) in respect of other taxes on income, for taxes chargeable for any tax year
      beginning on or after the first day of January in the calendar year next following the year in
      which the notice is given;</p>
                    <p>b) in Barbados:</p>
                    <p>(i) in respect of taxes withheld at source, on amounts paid or remitted to
      non-residents on or after the first day of January next following the notice of
      termination;</p>
                    <p>(ii) in respect of other taxes on income derived on or after the first day of January
      next following the notice of termination.</p>
                    <p>In witness whereof the undersigned, duly authorised thereto, have signed this
      Convention.</p>
                    <p>Done in duplicate at London this 15 day of June 1989, in the Finnish and English
      languages, both texts being equally authentic.</p>
                </content>
            </article>
            <hcontainer name="attachments">
                <hcontainer eId="protocol" name="attachment">
                    <heading>Protocol amending the Convention Finland and Barbados for the avoidance of double taxation with respect to taxes on income signed at London on 15 June 1989</heading>
                    <content>
                        <p>The Government of Finland and the Government of Barbados,</p>
                        <p>Desiring to amend the Convention for the Avoidance of Double Taxation with respect to
      Taxes on Income, signed at London on 15 June 1989 (hereinafter referred to as "the
      Convention");</p>
                        <p>Have agreed as follows:</p>
                        <tblock>
                            <num>Article 1</num>
                            <p>Paragraph 2 of Article 27 of the Convention shall be deleted and replaced by the
        following:</p>
                            <p>– – </p>
                        </tblock>
                        <tblock>
                            <num>Article 2</num>
                            <p>Article 29 of the Convention shall be deleted and replaced by the
        following:</p>
                            <p>– – </p>
                        </tblock>
                        <tblock>
                            <num>Article 3</num>
                            <p>1. The Governments of the Contracting States shall notify each other that the
        constitutional requirements for the entry into force of this Protocol have been complied
        with.</p>
                            <p>2. The Protocol shall enter into force thirty days after the date of the later of
        the notifications referred to in paragraph 1 and shall thereupon have effect as from that
        date.</p>
                            <p>The provisions of this Protocol shall also apply in their terms to information
        predating the coming into force of this Protocol.</p>
                            <p>In witness whereof the undersigned, duly authorized thereto, have signed this
        Protocol.</p>
                            <p>Done in duplicate at Paris, this 3rd day of November 2011 in the English
        language.</p>
                        </tblock>
                    </content>
                </hcontainer>
            </hcontainer>
        </mainBody>
    </doc>
</akomaNtoso>
