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        <preface>
            <p>
                <docNumber>11-12/1966</docNumber>
                <docTitle>Convention between the Government of the Republic of Finland and the Government of the United Arab Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income</docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF FINLAND AND THE GOVERNMENT OF THE UNITED ARAB REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME</heading>
                        <p>This document presents the synthesised text for the application of the Convention
      between the Government of the Republic of Finland and the Government of the United Arab
      Republic for the avoidance of double taxation and the prevention of fiscal evasion with
      respect to taxes on income signed on 1 April 1965 and the Exchange of Notes done on 6 July
      1974 (the “Conventionˮ), as modified by the Multilateral Convention to Implement Tax Treaty
      Related Measures to Prevent Base Erosion and Profit Shifting signed by the Republic of Finland
      and the Arab Republic of Egypt on 7 June 2017 (the “MLIˮ).</p>
                        <p>This document was prepared by the competent authority of Finland and represents its
      understanding of the modifications made to the Agreement by the MLI.</p>
                        <p>The document was prepared on the basis of the MLI position of the Republic of Finland
      submitted to the Depositary upon acceptance on 25 February 2019 and of the MLI position of the
      Arab Republic of Egypt submitted to the Depositary upon ratification on 30 September 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 this Convention. The document also
      contains the modifications resulting from the withdrawal of the reservation made by the
      Republic of Finland to Article 9 of the MLI (consolidated MLI position of the Republic of
      Finland on 27 June 2023).</p>
                        <p>The authentic legal texts of the Convention and the MLI take precedence and remain the
      legal texts applicable. Whereas the Convention as presented in this synthesised text
      incorporates changes contained in the Exchange of Notes (done on 6 July 1974) into the
      original 1965 Convention for readability, the 1965 Convention and the Exchange of Notes (done
      on 6 July 1974) 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
      Agreementˮ and “Conventionˮ, “Contracting Jurisdictionsˮ and “Contracting Statesˮ), to ease
      the comprehension of the provisions of the MLI. The changes in terminology are intended to
      increase the readability of the document and are not intended to change the substance of the
      provisions of the MLI.</p>
                        <p>In all cases, references made to the provisions of the Convention or to the Convention
      must be understood as referring to the Convention as modified by the provisions of the MLI,
      provided such provisions of the MLI have taken effect.</p>
                        <p>
                            <b>Entry into Effect of the MLI Provisions</b>
                        </p>
                        <p>The provisions of the MLI applicable to this Convention do not take effect on the same
      dates as the original provisions of the Convention. Each of provisions of the MLI could take
      effect on different dates, depending on the types of taxes involved (taxes withheld at source
      or other taxes levied) and on the choices made by the Republic of Finland and the Arab
      Republic of Egypt in their MLI positions.</p>
                        <p>Dates of the deposit of instruments of ratification, acceptance or approval: 25
      February 2019 for the Republic of Finland and 30 September 2020 for the Arab Republic of
      Egypt.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 January
      2021 for the Arab Republic of Egypt.</p>
                        <p>This document provides specific information on the dates on or after which each of the
      provisions of the MLI has effect with respect to the Convention throughout this
      document.</p>
                        <p>
                            <b>References</b>
                        </p>
                        <p>The authentic legal texts of the MLI can be found on the MLI Depositary (OECD)
      webpage:</p>
                        <p>
                            – in English:
                            <a href="http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf">http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf</a>
                                  and
                        </p>
                        <p>
                            – in French:
                            <a href="http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf">http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf</a>
                        </p>
                        <p>
                            The MLI position of the Republic of Finland submitted to the Depositary upon
      acceptance on 25 February 2019, the consolidated MLI position of the Republic of Finland
      submitted to the Depositary on 27 June 2023 and the MLI position of the Arab Republic of Egypt
      submitted to the Depositary upon ratification on 30 September 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 the
      Arab Republic of Egypt is published in the Treaty Series of the Statute Book of Finland SopS
      111/2020. Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2020/20200111">https://finlex.fi/fi/sopimukset/sopsteksti/2020/20200111</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2020/fds20200111.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2020/fds20200111.pdf</a>
                        </p>
                        <p>
                            Convention between the Government of the Republic of Finland and the Government of the
      United Arab Republic for the avoidance of double taxation and the prevention of fiscal evasion
      with respect to taxes on income signed on 1 April 1965 is published in the Treaty Series of
      the Statute Book of Finland SopS 12/1966. Link to Finnish language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1966/19660012">https://www.finlex.fi/fi/sopimukset/sopsteksti/1966/19660012</a>
                        </p>
                        <p>
                            Exchange of Notes done on 6 July 1974 is published in the Treaty Series of the Statute
      Book of Finland SopS 56/1976. Link to Finnish language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1976/19760056">https://www.finlex.fi/fi/sopimukset/sopsteksti/1976/19760056</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Convention between the Government of the Republic of Finland and the Government of the United Arab Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income</p>
            <p>The Government of the Republic of Finland and the Government of the United Arab
    Republic,</p>
            <p>
                <embeddedStructure class="mli-replaced">
                    <p>
                        <authorialNote>
                            <p>[REPLACED by paragraph 1 of Article 6 of the MLI]</p>
                        </authorialNote>
                    </p>
                    <p>[Desiring to conclude a Convention for the avoidance of double taxation and the
      prevention of fiscal evasion 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 2021;
          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 the Arab
          Republic of Egypt:</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 2021;
          and</p>
                                    <p>b) with respect to all other taxes levied by the the Arab Republic of Egypt, for
          taxes levied with respect to taxable periods beginning on or after 1 July 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>
            <chapter eId="chp_1">
                <num>Chapter I</num>
                <heading>Scope of the Convention</heading>
                <article eId="chp_1__art_1">
                    <num>Article 1</num>
                    <heading>Personal scope</heading>
                    <content>
                        <p>This Convention shall apply to persons who are residents of one or both of the
        Contracting States.</p>
                    </content>
                </article>
                <article eId="chp_1__art_2">
                    <num>Article 2</num>
                    <heading>Taxes covered</heading>
                    <content>
                        <p>1. This Convention shall apply to taxes on income imposed on behalf of each
        Contracting State or of its subdivisions or on behalf of a public community, irrespective of
        the manner in which they are levied.</p>
                        <p>2. There shall be regarded as taxes on income all taxes imposed on total income, or
        on all elements of income including taxes on gains from the alienation of movable or
        immovable property and taxes on the total amounts of wages or salaries paid by
        enterprises.</p>
                        <p>3. The existing taxes to which the Convention shall apply are in
        particular:</p>
                        <p>a) In the case of Finland:</p>
                        <p>1) State income tax;</p>
                        <p>2) Communal tax;</p>
                        <p>3) Sailors' tax;</p>
                        <p>(hereinafter referred to as "Finnish tax").</p>
                        <p>b) ln the case of the United Arab Republic:</p>
                        <p>1) Tax on income derived from immovable property (including the land tax, the
        buildings tax and the ghaffir tax);</p>
                        <p>2) Tax on income from movable capital;</p>
                        <p>3) Tax on commercial and industrial profits;</p>
                        <p>4) Tax on wages, salaries, indemnities and pensions;</p>
                        <p>5) Tax on profits from liberal professions and all other non-commercial
        professions;</p>
                        <p>6) General income tax;</p>
                        <p>7) Defence tax;</p>
                        <p>8) Supplementary taxes imposed as a percentage of taxes mentioned above or
        otherwise;</p>
                        <p>(hereinafter referred to as "United Arab Republic tax").</p>
                        <p>4. The Convention shall also apply to any identical or substantially similar taxes
        which are subsequently imposed in addition to, or in the place of, the existing
        taxes.</p>
                        <p>5. At the end of each year, the competent authorities of the Contracting States
        shall notify to each other any significant changes which have been made in their respective
        taxation laws.</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_2">
                <num>Chapter II</num>
                <heading>Definitions</heading>
                <article eId="chp_2__art_3">
                    <num>Article 3</num>
                    <heading>General definitions</heading>
                    <content>
                        <p>1. In this Convention, unless the context otherwise requires:</p>
                        <p>a) The term "Finland" means the Republic of Finland;</p>
                        <p>b) the term "United Arab Republic" means Egypt;</p>
                        <p>c) the terms "a Contracting State" and "the other Contracting State" mean Finland or
        the United Arab Republic, as the context requires;</p>
                        <p>d) the term "tax" means Finnish tax or United Arab Republic tax, as the context
        requires;</p>
                        <p>e) the term "person" includes individuals, companies and all other entities which
        are treated as taxable units under the tax laws in force in either Contracting
        State;</p>
                        <p>f) the term "company" means any body corporate or any entity which is treated as a
        body corporate for tax purposes;</p>
                        <p>g) the terms "enterprise of a Contracting State" and "enterprise of the other
        Contracting State" mean respectively an enterprise carried on by a resident of a Contracting
        State and an enterprise carried on by a resident of the other Contracting State;</p>
                        <p>h) the term "competent authorities" means in the case of Finland the Ministry of
        Finance and in the case of the United Arab Republic, the Ministry of Treasury.</p>
                        <p>2. In the application of the provisions of this Convention by one of the Contracting
        States any term not otherwise defined shall, unless the context otherwise requires, have the
        meaning which it has under the laws in force in that State relating to the taxes which are
        the subject of this Convention.</p>
                    </content>
                </article>
                <article eId="chp_2__art_4">
                    <num>Article 4</num>
                    <heading>Fiscal domicile</heading>
                    <content>
                        <p>1. For the purposes of this Convention, the term "resident of a Contracting State"
        means any person who, under the law of that State, is liable to taxation therein by reason
        of his domicile, residence, place of management or any other criterion of a similar
        nature.</p>
                        <p>2. Where by reason of the provisions of paragraph 1 an individual is a resident of
        both Contracting States, then this case shall be determined in accordance with the following
        rules:</p>
                        <p>a) He shall be deemed to be a resident of the Contracting State in which he has a
        permanent home available to him. If he has a permanent home available to him in both
        Contracting States, he shall be deemed to be a resident of the Contracting State with which
        his personal and economic relations are closest (centre of vital interests);</p>
                        <p>b) If the Contracting 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 Contracting State,
        he shall be deemed to be a resident of the Contracting State in which he has an habitual
        abode;</p>
                        <p>c) If he has an habitual abode in both Contracting States or in neither of them, he
        shall be deemed to be a resident of the Contracting State of which he is a
        national;</p>
                        <p>d) If he is a national of both Contracting States or of neither of them, the
        competent authorities of the Contracting States shall settle the question by mutual
        agreement.</p>
                        <p>3. Where by reason of the provisions of paragraph 1 a person other than an
        individual is a resident of both Contracting States, then it shall be deemed to be a
        resident of the Contracting State in which its place of effective management is
        situated.</p>
                    </content>
                </article>
                <article eId="chp_2__art_5">
                    <num>Article 5</num>
                    <heading>Permanent establishment</heading>
                    <content>
                        <p>1. For the purposes of this Convention, the term "permanent establishment" means a
        fixed place of business in which the business of tbc enterprise is wholly or partly carried
        on.</p>
                        <p>2. The term "permanent establishment" shall include especially:</p>
                        <p>a) a place of management;</p>
                        <p>b) a branch;</p>
                        <p>c) an office;</p>
                        <p>d) a factory;</p>
                        <p>e) a workshop;</p>
                        <p>f) a mine, a quarry, an oilfield or other place of extraction of natural
        resources;</p>
                        <p>g) a farm, a plantation and a warehouse;</p>
                        <p>h) a building site or construction or assembly project which exists for more than
        six months.</p>
                        <p>3. The term "permanent establishment" shall not be deemed to include:</p>
                        <p>a) the use of facilities solely for the purpose of storage, display or delivery of
        goods or merchandise belonging to the enterprise;</p>
                        <p>b) the maintenance of a stock of goods or merchandise belonging to the enterprise
        solely for the purpose of storage, display or delivery;</p>
                        <p>c) the maintenance of a stock of goods or merchandise belonging to the enterprise
        solely for the purpose of processing by another enterprise;</p>
                        <p>d) the maintenance of a fixed place of business solely for the purpose of purchasing
        goods or merchandise, or for collecting information, for the enterprise;</p>
                        <p>e) the maintenance of a fixed place of business solely for the purpose of
        advertising, for the supply of information, for scientific research or for similar
        activities which have a preparatory or auxiliary character, for the enterprise.</p>
                        <p>4. A person acting in a Contracting State on behalf of an enterprise of the other
        Contracting State − other than an agent of an independent status to whom paragraph 5 applies
        − shall be deemed to be a permanent establishment in the first-mentioned State if he has and
        habitually exercises in that State, an authority to conclude contracts in the name of the
        enterprise, unless his activities are limited to the purchase of goods or merchandise for
        the enterprise.</p>
                        <p>5. An enterprise of a Contracting State shall not be deemed to have a permanent
        establishment in the other Contracting State merely because it carries on business in that
        other State through a broker, general commission agent or any other agent of an independent
        status where such persons are acting in the ordinary course of their business.</p>
                        <p>6. The fact that a company which is a resident of a Contracting State controls or is
        controlled by a company which is a resident of the other Contracting State, or which carries
        on business in that other State (whether through a permanent establishment or otherwise)
        shall not of itself constitute either company a permanent establishment of the
        other.</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_3">
                <num>Chapter III</num>
                <heading>Taxation of income</heading>
                <article eId="chp_3__art_6">
                    <num>Article 6</num>
                    <heading>Income from immovable property</heading>
                    <content>
                        <p>1. Income from immovable property may be taxed in the Contracting State in which
        such property is situated.</p>
                        <p>2. The term "immovable property" shall be defined in accordance with the law of the
        Contracting State in which the property in question is situated. The term shall in any case
        include property accessory to immovable property, livestock and equipment used in
        agriculture and forestry, rights to which the provisions of general law respecting land
        property apply, usufruct of immovable property and rights to variable or fixed payments as
        consideration for the working of, or the right to work, mineral deposits, sources and other
        natural resources. Ships and aircraft shall not be regarded as immovable
        property.</p>
                        <p>3. The provisions of paragraph 1 shall apply to income derived from the direct use,
        letting, or use in any other form of immovable property.</p>
                        <p>4. 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 professional services.</p>
                    </content>
                </article>
                <article eId="chp_3__art_7">
                    <num>Article 7</num>
                    <heading>Business profits</heading>
                    <content>
                        <p>1. The profits of an enterprise of a Contracting State shall be taxable only in that
        State unless the enterprise carries on business in the other Contracting State through a
        permanent establishment situated therein. If the enterprise carries on business as
        aforesaid, the profits of the enterprise may be taxed in the other State but only so much of
        them as is attributable to that permanent establishment.</p>
                        <p>2. Where an enterprise of a Contracting State carries on business in the other
        Contracting State through a permanent establishment situated therein, there shall in each
        Contracting State be attributed to that permanent establishment the profits which it might
        be expected to make if it were a distinct and separate enterprise engaged in the same or
        similar activities under the same or similar conditions and dealing wholly independently
        with the enterprise of which it is a permanent establishment.</p>
                        <p>3. In the determination of the profits of a permanent establishment, there shall be
        allowed as deductions expenses which are incurred for the purpose of the permanent
        establishment including executive and general administrative expenses so incurred, whether
        in the State in which the permanent establishment is situated or elsewhere.</p>
                        <p>4. Insofar as it has been customary in a Contracting State to determine the profits
        to be attributed to a permanent establishment on the basis of an apportionment of the total
        profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that
        Contracting State from determining the profits to be taxed by such an apportionment as may
        be customary; the method of apportionment adopted shall, however, be such that the result
        shall be in accordance with the principles laid down in this Article.</p>
                        <p>5. No profits shall be attributed to a permanent establishment by reason of the mere
        purchase by that permanent establishment of goods or merchandise for the
        enterprise.</p>
                        <p>6. For the purposes of the preceding paragraphs, the profits to be attributed to the
        permanent establishment shall be determined by the same method year by year unless there is
        good and sufficient reason to the contrary.</p>
                        <p>7. Where profits include items of income which are dealt with separately in other
        Articles of this Convention, then the provisions of these Articles shall not be affected by
        the provisions of the present Article.</p>
                    </content>
                </article>
                <article eId="chp_3__art_8">
                    <num>Article 8</num>
                    <heading>Shipping und air transport</heading>
                    <content>
                        <p>1. Profits from the operation of ships or aircraft in international traffic shall be
        taxable only in the Contracting State in which the place of effective management of the
        enterprise is situated.</p>
                        <p>2. The provisions of paragraph 1 shall likewise apply in respect of participations
        in pools of any kind by Finnish or United Arab Republic enterprises engaged in shipping or
        air transport.</p>
                        <p>3. Where profits as referred to in this Article are derived by a company which is a
        resident of a Contracting State, dividends paid by that company to persons which are not
        resident in the other Contracting State, shall be exempt from tax in that other
        State.</p>
                    </content>
                </article>
                <article eId="chp_3__art_9">
                    <num>Article 9</num>
                    <heading>Associated enterprises</heading>
                    <content>
                        <p>1. Where</p>
                        <p>a) an enterprise of a Contracting State participates directly or indirectly in the
        management, control or capital of an enterprise of the other Contracting State,
        or</p>
                        <p>b) the same persons participate directly or indirectly in the management, control or
        capital of an enterprise of a Contracting State and an enterprise of the other Contracting
        State, 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. If the information available to the taxation authority concerned is inadequate to
        determine, for the purposes of paragraph 1 of this Article, the profits which might be
        expected to accrue to an enterprise, nothing in that paragraph shall affect the application
        of the law of either Contracting State in relation to the liability of that enterprise to
        pay tax on an amount determined by the exercise of a discretion or the making of an estimate
        by the taxation authority of that State. Provided that such discretion shall be exercised or
        such estimate shall be made, so far as the information available to the taxation authority
        permits, in accordance with the principle stated in that paragraph.</p>
                    </content>
                </article>
                <article eId="chp_3__art_10">
                    <num>Article 10</num>
                    <heading>Dividends</heading>
                    <content>
                        <p>1. Dividends paid by a company which is a resident of Finland to a resident of the
        United Arab Republic may be taxed in Finland at a rate not exceeding 10 per cent of the
        gross amount of the dividend.</p>
                        <p>2. Dividends paid by a company which is a resident of the United Arab Republic to a
        resident of Finland may be taxed in the United Arab Republic. But such dividends shall only
        be subject to the tax on income derived from movable capital, the supplementary taxes and
        the defence tax (which taxes shall be deducted at the source). Dividends paid shall be
        deducted from the amount of the distributing company's taxable income or profits subject to
        the tax chargeable in respect of its industrial and commercial profits such dividends are
        distributed out of the taxable profits of the same taxable year and not distributed out of
        accumulated reserves or other assets. If such dividends are paid to a natural person also
        the general income tax levied on the net total income may be imposed, provided that such
        dividends shall not be subject to general income tax at a rate in excess of 20 per
        cent.</p>
                        <p>3. Dividends paid by a company which is a resident of Finland whose activities lie
        solely or mainly in the United Arab Republic, shall in the United Arab Republic be treated
        as mentioned in paragraph 2 of this Article.</p>
                        <p>4. Dividends, deemed to be paid out of the yearly profits of a permanent
        establishment maintained in the United Arab Republic by a Finnish company whose activities
        extend to countries other than the United Arab Republic, shall in the United Arab Republic
        be treated as mentioned in paragraph of this Article.</p>
                        <p>The permanent establishment shall be considered to have distributed as dividends in
        the United Arab Republic within 60 days from the closing of its financial year an amount
        equivalent to 90 per cent of its total net profits liable to the tax on industrial and
        commercial profits without applying the provisions of Article 36 of law 14 of 1939, provided
        that the remaining 10 per cent of the net profits shall be set aside to form a special
        reserve which shall be entered in the local balance sheet submitted annually to the United
        Arab Republic tax authorities. Such amount shall only be subject to the tax on commercial
        and industrial profits.</p>
                        <p>All amounts deducted from the aforesaid 10 per cent set aside to form the special
        reserve for purposes other than the redemption of losses incurred in the trade or business
        carried on by that permanent establishment situated in the United Arab Republic shall be
        deemed to have been distributed m the United Arab Republic and shall be taxed
        accordingly.</p>
                        <p>5. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the
        dividends, being a resident of a Contracting State, has in the other Contracting State, of
        which the company paying the dividends is a resident, a permanent establishment with which
        the holding by virtue of which the dividends are paid is effectively connected. In such a
        case, Article 7 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, such other State may not impose any tax on the
        dividends paid by the company to persons who are not residents of that other State, or
        subject the company's undistributed profits to a tax on undistributed profits, even if the
        dividends paid or the undistributed profits consist wholly or partly of profits or income
        arising in such other State.</p>
                        <p>7. The term "dividends" as used in this Article means income from shares
        "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other similar
        rights, not being debt-claims, participating in profits, as well as income from other
        corporate rights assimilated to income from shares by the taxation law of the State of which
        the company making the distribution is a resident.</p>
                    </content>
                </article>
                <article eId="chp_3__art_11">
                    <num>Article 11</num>
                    <heading>Interest</heading>
                    <content>
                        <p>1. Interest paid by a resident of Finland to a resident of the United Arab Republic
        shall be exempt from Finnish tax.</p>
                        <p>2. Interest paid by a resident of the United Arab Republic to a resident of Finland
        may be taxed in the United Arab Republic. But such interest shall only be subject to the tax
        on income derived from movable capital, the supplementary taxes and the defence tax (which
        taxes shall be deducted at the source). If paid to a natural person also the general income
        tax levied on the net total income may be imposed, provided that such interest shall not be
        subject to general income tax at a rate in excess of 15 per cent.</p>
                        <p>3. The term "interest" as used in this Article means income from Government
        securities, bonds or debentures, (exclusive of interest on debts secured by mortgages on
        real estate, in which case Article 6 shall apply) whether or not carrying a right to
        participate in profits, and debt-claims of every kind as well as all other income
        assimilated to income from money lent by the taxation law of the State in which the income
        arises.</p>
                        <p>4. The provisions of paragraphs 1 and 2 shall not apply if the recipient of the
        interest, being a resident of a Contracting State, has in the other Contracting State in
        which the interest arises a permanent establishment with which the debt-claim from which the
        interest arises is effectively connected. In such a case, Article 7 shall apply.</p>
                        <p>5. Where, owing to a special relationship between the payer and the recipient or
        between both of them and some other person, the amount of the interest l)aid, having regard
        to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon
        by the payer and the recipient in the absence of such relationship, the provisions of this
        Article shall apply only to the last mentioned amount. In that case, the excess part of the
        payments shall remain taxable according to the law of each Contracting State.</p>
                        <p>6. Interest shall be deemed to arise in a Contracting State when the payer is that
        State itself, a subdivision, a public community or a resident of that State. Where, however,
        the person paying the interest, whether he is a resident of a Contracting State or not, has
        in a Contracting State a permanent establishment in connection with which the indebtedness
        on which the interest is paid was incurred, and such interest is borne by such permanent
        establishment, then such interest shall be deemed to arise in the Contracting State in which
        the permanent establishment is situated.</p>
                    </content>
                </article>
                <article eId="chp_3__art_12">
                    <num>Article 12</num>
                    <heading>Royalties</heading>
                    <content>
                        <p>1. Royalties arising in a Contracting State and paid to a resident of the other
        Contracting State may be taxed in the first-mentioned State at a rate not exceeding 25 per
        cent of its gross value.</p>
                        <p>2. The term "royalties" as used in this Article means payments of any kind received
        as consideration for the use of, or the right to use, any copyright of literary, artistic or
        scientific work, any patent, trade mark, design or model, plan, secret formula or process,
        or for the use of, or the right to use, industrial, commercial or· scientific equipment or
        for information concerning industrial, commercial or scientific experience.</p>
                        <p>3. Notwithstanding any provision of this Convention rents and royalties in respect
        of cinematographic films may continue to be taxed under the laws of the two Contracting
        States.</p>
                        <p>4. The provisions of paragraph 1 shall not apply where founders' shares are issued
        in the United Arab Republic as consideration for the rights mentioned in paragraph 2 of this
        Article and taxed in accordance with the provisions of Article 1 of Law 14 of 1939. In such
        event Article 10 of this Convention shall be applicable.</p>
                        <p>5. The provisions of paragraph 1 shall not apply if the recipient of the royalties,
        being a resident of a Contracting State, has in the other Contracting State in which the
        royalties arise a permanent establishment with which the right or property giving rise to
        the royalties is effectively connected. In such a case, Article 7 shall apply.</p>
                        <p>6. Where, owing to a special relationship between the payer and the recipient or
        between both of them and some other person, the amount of the royalties paid, having regard
        to the use, right or information for which they are paid, exceeds the amount which would
        have been agreed upon by the payer and the recipient in the absence of such relationship,
        the provisions of this Article shall apply only to the last-mentioned amount. In that case,
        the excess part of the payments shall remain taxable according to the law of each
        Contracting State.</p>
                        <p>7. A royalty shall be deemed to arise in in a Contracting State when the payer is
        that State itself, a subdivision, a public community or a resident of that State. Where,
        however, the person paying royalty, whether he is a resident of a Contracting State or not,
        has in a Contracting State a permanent establishment by which the royalty is paid, then such
        royalty shall be deemed to arise in the Contracting State in which the permanent
        establishment is situated.</p>
                    </content>
                </article>
                <article eId="chp_3__art_13">
                    <num>Article 13</num>
                    <heading>Capital gains</heading>
                    <content>
                        <p>1. Gains from the alienation of immovable property, as defined in paragraph 2 of
        Article 6, may be taxed in the Contracting State in which such property is
        situated.</p>
                        <p>2. Gains from the alienation of movable property forming part of the business
        property employed in 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 professional services, including such gains from the alienation of
        such a permanent establishment (alone or together with the whole enterprise) or of such a
        fixed base, may be taxed in the other State. However, gains from the alienation of movable
        property of the kind referred to in paragraph 1 of Article 8, shall be taxable only in the
        Contracting State in which such movable property is taxable according to the said
        Article.</p>
                        <p>3. Gains from the alienation of any property or assets other than those mentioned in
        paragraphs 1 and 2, shall be taxable only in the State where the income arises.</p>
                        <p>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following paragraph 4 of Article 9 of the MLI applies and supersedes the
          provisions of this Convention:
                                            <authorialNote marker="2" placement="bottom">
                                                <p>In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of
              the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the
              application of this Convention by the Republic of Finland: </p>
                                                <p>a) with respect to taxes withheld at source on amounts paid or credited to
              non-residents, where the event giving rise to such taxes occurs on or after 1 January
              2024; and</p>
                                                <p>b) with respect to all other taxes levied by the Republic of Finland, for
              taxes levied with respect to taxable periods beginning on or after 1 January
              2024;</p>
                                                <p>and,</p>
                                                <p>In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of
              the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the
              application of the Convention by the Arab Republic of Egypt: </p>
                                                <p>a) with respect to taxes withheld at source on amounts paid or credited to
              non-residents, where the event giving rise to such taxes occurs on or after 1 January
              2024; and</p>
                                                <p>b) with respect to all other taxes levied by the Arab Republic of Egypt, for
              taxes levied with respect to taxable periods beginning on or after 1 January
              2024.</p>
                                            </authorialNote>
                                        </p>
                                    </authorialNote>
                                </p>
                                <article>
                                    <num>ARTICLE 9 OF THE MLI – CAPITAL GAINS FROM ALIENATION OF SHARES OR INTERESTS OF ENTITIES DERIVING THEIR VALUE PRINCIPALLY FROM IMMOVABLE PROPERTY</num>
                                    <content>
                                        <p>
                                            For purposes of [
                                            <i>the Convention</i>
                                            ], gains derived by a
            resident of a [
                                            <i>Contracting State</i>
                                            ] from the alienation of shares
            or comparable interests, such as interests in a partnership or trust, may be taxed in
            the other [
                                            <i>Contracting State</i>
                                            ] if, at any time during the 365 days
            preceding the alienation, these shares or comparable interests derived more than 50 per
            cent of their value directly or indirectly from immovable property (real property)
            situated in that other [
                                            <i>Contracting State</i>
                                            ].
                                        </p>
                                    </content>
                                </article>
                            </embeddedStructure>
                        </p>
                    </content>
                </article>
                <article eId="chp_3__art_14">
                    <num>Article 14</num>
                    <heading>Independent personal services</heading>
                    <content>
                        <p>1. Income derived by a resident of a Contracting State in respect of professional
        services or other independent activities of a similar character shall be taxable only in
        that State unless he has a fixed base regularly available to him in tb other Contracting
        State for the purpose of performing his activities or he is present within that State for a
        period or periods exceeding in the aggregate 183 days in the fiscal year concerned. If he
        has such a fixed base or remains in that State for the aforesaid period, the income may be
        taxed in the other Contracting State but only so much of it as is attributable to that fixed
        base or the period aforementioned.</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, dentists, lawyers, engineers, architects and accountants.</p>
                    </content>
                </article>
                <article eId="chp_3__art_15">
                    <num>Article 15</num>
                    <heading>Dependent personal services</heading>
                    <content>
                        <p>1. Subject to the provisions of Articles 16, 18, 19, 20 and 21 salaries, wages and
        other similar remuneration derived by a resident of a Contracting State in respect of an
        employment shall be taxable only in that State unless the employment is exercised in the
        other Contracting State. If the employment is so exercised, such remuneration as is derived
        therefrom may be taxed in that other State.</p>
                        <p>2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident
        of a Contracting State in respect of an employment exercised in the other Contracting State
        shall be taxable only in the first-mentioned State if:</p>
                        <p>a) the recipient is present in the other State for a period or periods not exceeding
        in the aggregate 183 days in the fiscal year concerned, and</p>
                        <p>b) the remuneration is paid by, or on behalf of an employer who is not a resident of
        the other State, and</p>
                        <p>c) the remuneration is not borne by a permanent establishment or a fixed base which
        the employer has in the other State.</p>
                        <p>3. Notwithstanding the preceding provisions of this Article, remuneration in respect
        of an employment exercised aboard a ship or aircraft in international traffic, may be taxed
        in the Contracting State in which the place of effective management of the enterprise is
        situated.</p>
                    </content>
                </article>
                <article eId="chp_3__art_16">
                    <num>Article 16</num>
                    <heading>Directors' fees</heading>
                    <content>
                        <p>Directors' fees and similar payments derived by a resident of a Contracting State in
        his capacity as a member of the board of directors of a company which is a resident of the
        other Contracting State may be taxed in that other State.</p>
                    </content>
                </article>
                <article eId="chp_3__art_17">
                    <num>Article 17</num>
                    <heading>Artists and Athletes</heading>
                    <content>
                        <p>Notwithstanding the provision of Articles 14 and 15, income derived by public
        entertainers, such as theatre, motion picture, radio or television artists, and musicians,
        and by athletes, from their personal activities as such may be taxed in the Contracting
        State in which these activities are exercised.</p>
                    </content>
                </article>
                <article eId="chp_3__art_18">
                    <num>Article 18</num>
                    <heading>Pensions</heading>
                    <content>
                        <p>Subject to the provisions of paragraph 1 of Article 19, pensions and other similar
        remuneration paid to a resident of a Contracting State in consideration of past employment
        shall be taxable only in that State.</p>
                    </content>
                </article>
                <article eId="chp_3__art_19">
                    <num>Article 19</num>
                    <heading>Governmental and other public functions</heading>
                    <content>
                        <p>1. Remuneration, including pensions (also widows', orphans' and other legal
        beneficiaries' pensions), paid by, or out of funds created by, a Contracting State, a
        subdivision or by a public community to any individual in respect of services rendered to
        that State, subdivision or public community in the discharge of functions of a governmental
        or other public nature may be taxed in that State.</p>
                        <p>2. The provisions of paragraph 1 shall mutatis mutandis apply to such remuneration
        and pensions paid in Finland by the Bank of Finland and the National Pension Administration
        and in the United Arab Republic by the Central Bank, the Post, Railways, Telephone and
        Telegraph, Radio and Television organizations and by other general organizations engaged in
        public services of either Contracting State.</p>
                        <p>3. The provisions of articles 15, 16 and 18 shall apply to remuneration or pensions
        in respect of services rendered in connection with any trade or business other than those
        mentioned in paragraph 2 carried on by any of the legal entities mentioned in this
        article.</p>
                    </content>
                </article>
                <article eId="chp_3__art_20">
                    <num>Article 20</num>
                    <heading>Students</heading>
                    <content>
                        <p>A resident of one of the Contracting States, who is temporarily present in the other
        Contracting State solely:</p>
                        <p>a) as a student at a university, college or school in the latter Contracting
        State,</p>
                        <p>b) as a business or technical apprentice, or</p>
                        <p>c) as the recipient of a grant, allowance or award for the primary purpose of study
        or research from a religious, charitable, scientific or educational organization</p>
                        <p>shall not be taxed in the other Contracting State in respect of remittances from
        abroad for the purposes of his maintenance, education or training or in respect of a
        scholarship grant. The same shall apply to any amount representing remuneration for services
        rendered in that other State, provided that such services are in connection with his studies
        or training or are necessary for the purpose of his maintenance.</p>
                    </content>
                </article>
                <article eId="chp_3__art_21">
                    <num>Article 21</num>
                    <heading>Professors, Teachers and Researchers</heading>
                    <content>
                        <p>A resident of one of the Contracting States who, at the invitation of a university,
        college or other establishment for higher education or scientific research in the other
        Contracting State, visits that other State solely for the purpose of teaching or scientific
        research at such institution for a period not exceeding two years shall not be taxed in that
        other State in respect of his remuneration for such teaching or research.</p>
                    </content>
                </article>
                <article eId="chp_3__art_22">
                    <num>Article 22</num>
                    <heading>Income not expressly mentioned</heading>
                    <content>
                        <p>Items of income of a resident of a Contracting State, which are not expressly
        mentioned in the foregoing Articles of the Convention shall be taxable only in State where
        the income arises.</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_4">
                <num>Chapter IV</num>
                <heading>Method for elimination of double taxation</heading>
                <article eId="chp_4__art_23">
                    <num>Article 23</num>
                    <heading>Exemption and Credit methods</heading>
                    <content>
                        <p>1. Where a person being a resident of a Contracting State derives income from the
        other Contracting State and that income, in accordance with the provisions of this
        Convention, may be taxed in that other Contracting State, the first-mentioned State shall,
        subject to the provisions of paragraph 2, exempt such income from tax but may, in
        calculating tax on the remaining income of that person, apply the rate of tax which would
        have been applicable if the exempted income had not been so exempted.</p>
                        <p>2. Where a person being a resident of a Contracting State derives income from the
        other Contracting State and that income, in accordance with the provisions of Articles 10,
        11, and 12 may be taxed in that other Contracting State, the first-mentioned State shall
        allow as a deduction from the tax on the income of that person an amount equal to the tax
        paid in that other Contracting State. Such deduction shall not, however, exceed that part of
        the tax, as computed before the deduction is given, which is appropriate to the income
        derived from that other Contracting State.</p>
                        <p>3. Notwithstanding the provisions of paragraph 2 of this Article dividends paid by a
        company which is a resident of the Arab Republic of Egypt to a company which is resident of
        Finland shall be exempt from Finnish tax to the extent that the dividends would have been
        exempt from tax under Finnish law if both companies had been residents of Finland. (Sops
        55-56/1976)</p>
                    </content>
                </article>
            </chapter>
            <chapter eId="chp_5">
                <num>Chapter V</num>
                <heading>Special provisions</heading>
                <article eId="chp_5__art_24">
                    <num>Article 24</num>
                    <heading>Non-discrimination</heading>
                    <content>
                        <p>1. The 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 term "nationals" means:</p>
                        <p>a) all individuals possessing the nationality of a Contracting State;</p>
                        <p>b) all legal persons, partnerships and associations deriving their status as such
        from the law in force in a Contracting State.</p>
                        <p>3. The taxation on a permanent establishment which an enterprise of a Contracting
        State has in the other Contracting State shall not be less favourably levied in that other
        State than the taxation levied on enterprises of that other State carrying on the same
        activities.</p>
                        <p>This provision shall not be construed as obliging a Contracting State to grant to
        residents of the other Contracting State any personal allowances, reliefs and reductions for
        taxation purposes on account of civil status or family responsibilities which it grants to
        its own residents.</p>
                        <p>4. Enterprises o:f a Contracting State, the capital of which is wholly or partly
        owned or controlled, directly or indirectly, by one or more residents o:f the other
        Contracting State, shall not be subjected in the first-mentioned Contracting 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 that
        first-mentioned State are or may be subjected.</p>
                        <p>5. The provisions of this Article shall not be construed as affecting the
        application in the United Arab Republic of Article 11 paragraphs 1 and 2 and Article 11 bis
        of law 14 of 1939 and the exemptions conferred in the United Arab Republic by Articles 5 and
        6 of law 14 of 1939.</p>
                        <p>6. In this Article the term "taxation" means taxes of every kind and
        description.</p>
                    </content>
                </article>
                <article eId="chp_5__art_25">
                    <num>Article 25</num>
                    <heading>Mutual agreement procedure</heading>
                    <content>
                        <p>
                            <embeddedStructure class="mli-replaced">
                                <p>
                                    <authorialNote>
                                        <p>[REPLACED by the first sentence of paragraph 1 of Article 16 of the
          MLI]</p>
                                    </authorialNote>
                                </p>
                                <p>[1. Where a resident of a Contracting State considers that the actions of one or both
          of the Contracting States result or will result for him in taxation not in accordance with
          this Convention, he may, notwithstanding the remedies provided by the national laws of
          those States, present his case to the competent authority of the contracting State of
          which he is a resident.]</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 paragraph 1 of Article 25 of this Convention:
                                            <authorialNote marker="3" placement="bottom">
                                                <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, the first
              sentence of paragraph 1 of Article 16 of the MLI has effect with respect to the
              application of this Convention by the Republic of Finland:</p>
                                                <p>a) with respect to taxes withheld at source on amounts paid or credited to
              nonresidents, where the event giving rise to such taxes occurs on or after 1 January
              2021; 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 the Arab Republic of Egypt:</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
              2021; and</p>
                                                <p>b) with respect to all other taxes levied by the Arab Republic of Egypt, for
              taxes levied with respect to taxable periods beginning on or after 1 July
              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>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following second sentence of paragraph 1 of Article 16 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, the second
              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
              2021; 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 second sentence
              of paragraph 1 of Article 16 of the MLI has effect with respect to the application of
              the Convention by the Arab Republic of Egypt:</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
              2021; and</p>
                                                <p>b) with respect to all other taxes levied by the Arab Republic of Egypt, for
              taxes levied with respect to taxable periods beginning on or after 1 July
              2021.</p>
                                            </authorialNote>
                                        </p>
                                    </authorialNote>
                                </p>
                                <article>
                                    <num>ARTICLE 16 OF THE MLI – MUTUAL AGREEMENT PROCEDURE</num>
                                    <content>
                                        <p>
                                            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 [
                                            <i>the
              Convention</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 an appropriate 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 not in accordance with the Convention.</p>
                        <p>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following second sentence of paragraph 2 of Article 16 of the MLI applies
          to this Convention:
                                            <authorialNote marker="5" placement="bottom">
                                                <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, the second
              sentence of paragraph 2 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
              2021; 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 second sentence
              of paragraph 2 of Article 16 of the MLI has effect with respect to the application of
              the Convention the Arab Republic of Egypt:</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
              2021; and</p>
                                                <p>b) with respect to all other taxes levied by the Arab Republic of Egypt, for
              taxes levied with respect to taxable periods beginning on or after 1 July
              2021.</p>
                                            </authorialNote>
                                        </p>
                                    </authorialNote>
                                </p>
                                <article>
                                    <num>ARTICLE 16 OF THE MLI – MUTUAL AGREEMENT PROCEDURE</num>
                                    <content>
                                        <p>
                                            Any agreement reached shall be implemented notwithstanding any time limits in
            the domestic law of the [
                                            <i>Contracting States</i>
                                            ].
                                        </p>
                                    </content>
                                </article>
                            </embeddedStructure>
                        </p>
                        <p>3. The competent authorities of the Contracting States shall endeavour to resolve by
        mutual agreement any difficulties or doubts arising as to the interpretation or application
        of the Convention. They may also consult together for the elimination of double taxation in
        cases not provided for in the Convention.</p>
                        <p>4. The competent authorities of the Contracting States may communicate with each
        other directly for the purpose of reaching an agreement in the sense of the preceding
        paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of
        opinions, such exchange may take place through a Commission consisting of representatives of
        the competent authorities of the Contracting States.</p>
                    </content>
                </article>
                <article eId="chp_5__art_26">
                    <num>Article 26</num>
                    <heading>Exchange of information</heading>
                    <content>
                        <p>1. The competent authorities of the Contracting States shall exchange such
        information as is necessary for the carrying out of this Convention and of the domestic laws
        of the Contracting States concerning taxes covered by this Convention in so far as the
        taxation thereunder is in accordance with this Convention. Any information so exchanged
        shall be treated as secret and shall not be disclosed to any persons or authorities other
        than those concerned with the assessment, including judicial determination, or collection of
        the taxes which are the subject of this Convention.</p>
                        <p>2. In no case shall the provisions of paragraph 1 be construed so as to impose on
        one of the Contracting States the obligation:</p>
                        <p>a) to carry out administrative measures at variance with the laws or the
        administrative practice of that or of the other Contracting State;</p>
                        <p>b) to supply particulars which are not obtainable under the laws or in the normal
        course of the administration of that or of the other Contracting State;</p>
                        <p>c) to supply information which would disclose any trade, business, industrial,
        commercial or professional secret or trade process, or information, the disclosure of which
        would be contrary to public policy (ordre public).</p>
                    </content>
                </article>
                <article eId="chp_5__art_27">
                    <num>Article 27</num>
                    <heading>Diplomatic and consular privileges</heading>
                    <content>
                        <p>Nothing in the present Convention shall affect the fiscal privileges of diplomatic
        or consular officials under the general rules of international law or under the provisions
        of special agreements.</p>
                    </content>
                </article>
                <level>
                    <content>
                        <p>
                            <embeddedStructure class="mli-replacement">
                                <p>
                                    <authorialNote>
                                        <p>
                                            The following paragraph 1 of Article 7 of the MLI applies and supersedes the
        provisions of this Convention:
                                            <authorialNote marker="6" 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
            2021; 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 the Arab
            Republic of Egypt:</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
            2021; and</p>
                                                <p>b) with respect to all other taxes levied by the Arab Republic of Egypt, for
            taxes levied with respect to taxable periods beginning on or after 1 July
            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>
                    </content>
                </level>
            </chapter>
            <chapter eId="chp_6">
                <num>Chapter VI</num>
                <heading>Final provisions</heading>
                <article eId="chp_6__art_28">
                    <num>Article 28</num>
                    <heading>Entry into force</heading>
                    <content>
                        <p>1. This Convention shall be ratified and the instruments of ratification shall be
        exchanged at Helsinki as soon as possible.</p>
                        <p>2. This Convention shall enter into force thirty days after the exchange of the
        instruments of ratification and shall for the first time have effect:</p>
                        <p>a) In Finland:</p>
                        <p>to the income acquired in the calendar year in which this Convention comes into
        force or during any financial year closed on or after the date of entry into force of this
        Convention.</p>
                        <p>b) In the United Arab Republic:</p>
                        <p>1) as respects tax on income from movable capital and tax on wages, salaries,
        indemnities and pensions, which taxes are due on or after the date of entry into force of
        this Convention;</p>
                        <p>2) as respects tax on commercial and industrial profits for any period ending on or
        after the date of entry into force of this Convention;</p>
                        <p>3) as respects tax on income derived from immovable property, tax on liberal
        professions and all other non-commercial professions and the general income tax for the
        calendar year in which this Convention is in force.</p>
                        <p>The rules in subparagraph b) shall be correspondingly applicable respectively to the
        defence tax and to the supplementary taxes.</p>
                    </content>
                </article>
                <article eId="chp_6__art_29">
                    <num>Article 29</num>
                    <heading>Termination</heading>
                    <content>
                        <p>The present Convention shall remain in force until denounced by a Contracting State.
        Either Contracting State may denounce the Convention, through diplomatic channels, b giving
        notice of termination at least six months before the end of any calendar year after the year
        1970. ln such event, the Convention shall cease to have effect:</p>
                        <p>a) In Finland:</p>
                        <p>to the income acquired in the calendar year next following that in which the notice
        is given or to any financial year closed on or after the 1st day of January in the calendar
        year next following that in which the notice is given.</p>
                        <p>b) In the United Arab Republic:</p>
                        <p>1) as respects tax on income from movable capital and tax on wages, salaries,
        indemnities and pensions, which taxes are due on or after the 1st day of July in the
        calendar year next following that in which the notice is given:</p>
                        <p>2) as respects tax on commercial and industrial profits for any period ending on or
        after the 1st day of July in the calendar,year next following that in which the notice is
        given;</p>
                        <p>3) as respects tax on income derived from immovable property, tax on liberal
        professions and all other non-commercial professions and the general income tax for the
        calendar year next following that in which the notice is given.</p>
                        <p>The rules in subparagraph b) shall be correspondingly applicable respectively to the
        defence tax and to the supplementary taxes.</p>
                        <p>Done at Cairo, this first day of April, 1965, in duplicate in the English
        language.</p>
                    </content>
                </article>
            </chapter>
            <hcontainer name="attachments">
                <hcontainer name="attachment">
                    <heading>Exchange of Notes</heading>
                    <content>
                        <tblock>
                            <num>1.</num>
                            <heading>Ambassador of Finland to Minister for Foreign Affairs of the Arab Republic of Egypt</heading>
                            <p>Cairo, July 6, 1974</p>
                            <p>Excellency,</p>
                            <p>I have the honour to refer to the Convention between the Government of the Republic
        of Finland and the Government of the United Arab Republic for the Avoidance of Double
        Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at
        Cairo on April 1, 1965, and to the subsequent negotiation which have taken place between
        this Embassy and the Ministry for Foreign Affairs, and to propose that the following
        paragraph would be added to Article 23 of the Convention as new paragraph 3.</p>
                            <p>– – – – –</p>
                            <p>This new paragraph 3 of Article 23 shall enter into force on the 30th day after the
        date on which the governments of the Contracting States have notified to each other that the
        constitutional requirements for the entry into force of the new paragraph 3 of Article 23
        have been complied with, and shall thereupon have effect in respect of taxes on income
        acquired during the calendar year of 1966 or any accounting period closed in the course of
        that year or on income acquired thereafter."</p>
                            <p>If this proposal corresponds to the view of the Government of the Arab Republic of
        Egypt, I have the honour to propose that this Note and Your Excellency's reply thereto,
        shall constitute a Supplement to the Convention between the Government of Finland and the
        Government of the United Arab Republic for the Avoidance of Double Taxation and the
        Prevention of Fiscal Evasion with respect to Taxes on Income.</p>
                            <p>Accept, etc...</p>
                        </tblock>
                        <tblock>
                            <num>2.</num>
                            <heading>Minister for Foreign Affairs of the Arab Republic of Egypt to Ambassador of Finland</heading>
                            <p>Cairo, July 6th 1974</p>
                            <p>Mr. Ambassador</p>
                            <p>I have the honour to acknowledge receipt of your note of today's date, which reads
        as follows:</p>
                            <p>– – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – –</p>
                            <p>In reply, I have the honour to inform you that the aforementioned proposal is
        acceptable to the Government of the Arab Republic of Egypt, who therefore agree that your
        Note and the present Reply shall constitute a Supplement to the Convention between the
        Government of Finland and the Government of the United Arab Republic for the Avoidance of
        Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on
        Income.</p>
                            <p>Accept, etc...</p>
                        </tblock>
                    </content>
                </hcontainer>
            </hcontainer>
        </mainBody>
    </doc>
</akomaNtoso>
