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        <preface>
            <p>
                <docNumber>95-96/1993</docNumber>
                <docTitle>Convention between the Republic of Finland and the Republic of Estonia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital</docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE REPUBLIC OF FINLAND AND THE REPUBLIC OF ESTONIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL</heading>
                        <p>This document presents the synthesised text for the application of the Convention
      between the Republic of Finland and the Republic of Estonia for the Avoidance of Double
      Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital
      signed on 23rd March 1993 (the “Convention”), as modified by the Multilateral Convention to
      Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by
      the Republic of Finland on 7 June 2017 and by the Republic of Estonia on 29 June 2018 (the
      “MLI”).</p>
                        <p>This document was prepared in consultation with the competent authority of Estonia and
      represents a shared 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 the
      Republic of Estonia submitted to the Depositary upon ratification on 15 January 2021. These
      MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI
      positions could modify the effects of the MLI on the Convention. Also the notification made
      pursuant to Article 35(7)(b) of the MLI by the Republic of Estonia on 25 November 2021 was
      taken into account.</p>
                        <p>The authentic legal texts of the Convention and the MLI take precedence and remain the
      legal texts applicable.</p>
                        <p>The provisions of the MLI that are applicable with respect to the provisions of the
      Convention are included in boxes throughout the text of this document in the context of the
      relevant provisions of the Convention. The boxes containing the provisions of the MLI have
      generally been inserted in accordance with the ordering of the provisions of the OECD 2017
      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. </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 Republic of
      Estonia 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 15 January 2021 for the Republic of
      Estonia.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 May 2021
      for the Republic of Estonia. </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 and the MLI position of the Republic of Estonia submitted to
      the Depositary upon ratification on 15 January 2021 as well as the notification made pursuant
      to Article 35(7)(b) of the MLI by the Republic of Estonia on 25 November 2021 can be found on
      the MLI Depositary (OECD) webpage:
                            <a href="http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf">http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf</a>
                        </p>
                        <p>
                            The MLI Matching Database is publicly available on the OECD webpage:
                            <a href="http://www.oecd.org/tax/treaties/mli-matching-database.htm">http://www.oecd.org/tax/treaties/mli-matching-database.htm</a>
                        </p>
                        <p>
                            The Act on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent
      Base Erosion and Profit Shifting is published in Statute Book of Finland 231/2019. Link to
      Finnish language version
                            <a href="https://www.finlex.fi/fi/laki/alkup/2019/20190231">https://www.finlex.fi/fi/laki/alkup/2019/20190231</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/laki/alkup/2019/20190231">https://www.finlex.fi/sv/laki/alkup/2019/20190231</a>
                        </p>
                        <p>
                            The Government´s Statute on the entry into force of the MLI and the Act and the
      Finnish text (translation) of the MLI is published in the Treaty Series of the Statute Book of
      Finland SopS 21-22/2019. Links to Finnish language versions
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190021">https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190021</a>
                                  and
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190022">https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190022</a>
                        </p>
                        <p>
                            Links to Swedish language versions
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190021.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190021.pdf</a>
                                  and 
                        </p>
                        <p>
                            <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 the entry into force of the MLI in the
      Republic of Estonia is published in the Treaty Series of the Statute Book of Finland SopS
      23/2021. Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2021/20210023/20210023_1">https://finlex.fi/fi/sopimukset/sopsteksti/2021/20210023/20210023_1</a>
                                  Link to Swedish language version 
                        </p>
                        <p>
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2021/fds20210023.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2021/fds20210023.pdf</a>
                        </p>
                        <p>
                            The Convention between the Republic of Finland and the Republic of Estonia for the
      avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
      income and on capital signed on 23rd March 1993 is published in the Treaty Series of the
      Statute Book of Finland SopS 96/1993. Link to Finnish language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1993/19930096">https://www.finlex.fi/fi/sopimukset/sopsteksti/1993/19930096</a>
                        </p>
                        <p>
                            The Announcement of the Ministry of Finance of an amendment to the application of
      Article 12 of the Convention between the Republic of Finland and the Republic of Estonia for
      the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on
      Income and on Capital is published in the Treaty Series of the Statute Book of Finland SopS
      55/2016. Link to Finnish language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2016/20160055/20160055_1">https://www.finlex.fi/fi/sopimukset/sopsteksti/2016/20160055/20160055_1</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2016/fds20160055.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2016/fds20160055.pdf</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Convention between the Republic of Finland and the Republic of Estonia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital</p>
            <p>The Government of the Republic of Finland and the Government of the Republic of
    Estonia,</p>
            <p>Desiring to conclude a Convention for the avoidance of double taxation and the
    prevention of fiscal evasion with respect to taxes on income and on capital,</p>
            <p>
                <embeddedStructure class="mli-replacement">
                    <p>
                        <authorialNote>
                            <p>
                                The following paragraph 1 of Article 6 of the MLI is included in the preamble of
      this Convention:
                                <authorialNote marker="1" placement="bottom">
                                    <p>In accordance with paragraphs 1, 3 and 7 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 2023; </p>
                                    <p>and,</p>
                                    <p>In accordance with paragraphs 1, 3 and 7 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
          Republic of Estonia:</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 Estonia, for taxes
          levied with respect to taxable periods be-ginning on or after 1 January 2023.</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 taxes (valtion tuloverot; de statliga
      inkomstskatterna);</p>
                    <p>(ii) the corporate income tax (yhteisöjen tulovero; inkomstskatten för
      samfund);</p>
                    <p>(iii) the communal tax (kunnallisvero; kommunalskatten);</p>
                    <p>(iv) the church tax (kirkollisvero; kyrkoskatten);</p>
                    <p>(v) the tax withheld at source from interest (korkotulon lähdevero; källskatten på
      ränteinkomst);</p>
                    <p>(vi) the tax withheld at source from nonresidents’ income (rajoitetusti
      verovelvollisen lähdevero; källskatten för begränsat skattskyldig); and</p>
                    <p>(vii) the state capital tax (valtion varallisuusvero; den statliga
      förmögenhetsskatten);</p>
                    <p>(hereinafter referred to as ”Finnish tax”);</p>
                    <p>b) in Estonia:</p>
                    <p>(i) the personal income tax (üksikisiku tulumaks);</p>
                    <p>(ii) the corporate income tax (ettevõtte tulumaks); and</p>
                    <p>(iii) the licence tax (tegevusloa maks);</p>
                    <p>(hereinafter referred to as "Estonian tax").</p>
                    <p>2. Where a new tax on income or on capital is introduced in a Contracting State after
      the date of signature of the Convention, the Convention shall apply also to such tax. The
      competent authorities of the Contracting States shall by mutual agreement determine whether a
      tax which is introduced in either Contracting State is one to which the Convention shall apply
      according to the preceding sentence.</p>
                    <p>3. The Convention shall apply also to any taxes, being identical with or substantially
      similar to those mentioned or referred to in paragraphs I and 2, which are imposed after the
      date of signature of the Convention in addition to, or in place of, the taxes to which the
      Convention applies by virtue of those paragraphs. 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 "Estonia" means the Republic of Estonia and, when used in the geographic
      sense, means the territory of Estonia and any other area adjacent to the territorial waters of
      Estonia within which, under the laws of Estonia and in accordance with international law, the
      rights of Estonia may be exercised with respect to the sea bed and its sub-soil and their
      natural resources;</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:</p>
                    <p>(i) any individual possessing the nationality of a Contracting State;</p>
                    <p>(ii) any legal person, partnership or association deriving its status as such from the
      laws in force in a Contracting State;</p>
                    <p>g) the term "international traffic" means any transport by a ship or aircraft operated
      by an enterprise of a Contracting State, except when the ship or aircraft is operated solely
      between places in the other Contracting State;</p>
                    <p>h) the term "competent authority" means:</p>
                    <p>(i) in Finland, the Ministry of Finance, its authorised representative or the
      authority which, by the Ministry of Finance, is designated as competent authority;</p>
                    <p>(ii) in Estonia, 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>
            <tblock class="noteEditorial" eId="note_1" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1993/96#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <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, place of incorporation or any other criterion of a
      similar nature. The term also includes a Contracting State itself, and a local authority and a
      statutory body thereof. 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 or capital situated
      therein.</p>
                    <p>2. Where by reason of the provisions of paragraph 1 an individual is a resident of
      both Contracting States, then his status shall be determined as follows:</p>
                    <p>a) he shall be deemed to be a resident of the State in which he has a permanent home
      available to him; if he has a permanent home available to him in both States, he shall be
      deemed to be a resident of the State with which his personal and economic relations are closer
      (centre of vital interests);</p>
                    <p>b) if the State in which he has his centre of vital interests cannot be determined, or
      if he has not a permanent home available to him in either State, he shall be deemed to be a
      resident of the State in which he has an habitual abode;</p>
                    <p>c) if 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 endeavour to settle the question by mutual agreement and determine the mode of
      application of the Convention to such person. In the absence of such agreement, for the
      purposes of the Convention, the person shall in each Contracting State be deemed not to be a
      resident of the other Contracting State.</p>
                </content>
            </article>
            <article eId="art_5">
                <num>Article 5</num>
                <heading>Permanent establishment</heading>
                <content>
                    <p>1. For the purposes of this Convention, the term "permanent establishment" means a
      fixed place of business through which the business of an enterprise is wholly or partly
      carried on.</p>
                    <p>2. The term "permanent establishment" includes especially:</p>
                    <p>a) a place of management;</p>
                    <p>b) a branch;</p>
                    <p>c) an office;</p>
                    <p>d) a factory;</p>
                    <p>e) a workshop; and</p>
                    <p>f) a mine, an oil or gas well, a quarry or any other place of extraction of natural
      resources.</p>
                    <p>3. A building site, a construction, assembly or installation project or a supervisory
      or consultancy activity connected therewith constitutes a permanent establishment only if such
      site, project or activity lasts for a period of 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.</p>
                    <p>7. The fact that a company which is a resident of a Contracting State controls or is
      controlled by a company which is a resident of the other Contracting State, or which carries
      on business in that other State (whether through a permanent establishment or otherwise),
      shall not of itself constitute either company a permanent establishment of the
      other.</p>
                </content>
            </article>
            <article eId="art_6">
                <num>Article 6</num>
                <heading>Income from immovable property</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State from immovable property
      (including income from agriculture or forestry) situated in the other Contracting State may be
      taxed in that other State.</p>
                    <p>2. The term "immovable property" shall have the meaning which it has under the law of
      the Contracting State in which the property in question is situated. The term shall in any
      case include property accessory to immovable property, livestock and equipment used in
      agriculture and forestry, rights to which the provisions of general law respecting landed
      property apply, buildings, any option or similar right in respect of immovable property,
      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, boats and aircraft shall not be regarded as immovable property.</p>
                    <p>3. The provisions of paragraph 1 shall apply to income derived from the direct use,
      letting, or use in any other form of immovable property, as well as income from the alienation
      of immovable property.</p>
                    <p>4. Where the ownership of shares or other corporate rights in a company entitles the
      owner of such shares or corporate rights to the enjoyment of immovable property held by the
      company, the income from the direct use, letting, or use in any other form of such right to
      enjoyment may be taxed in the Contracting State in which the immovable property is
      situated.</p>
                    <p>5. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable
      property of an enterprise and to income from immovable property used for the performance of
      independent personal services.</p>
                </content>
            </article>
            <article eId="art_7">
                <num>Article 7</num>
                <heading>Business profits</heading>
                <content>
                    <p>1. The profits of an enterprise of a Contracting State shall be taxable only in that
      State unless the enterprise carries on business in the other Contracting State through a
      permanent establishment situated therein. If the enterprise carries on business as aforesaid,
      the profits of the enterprise may be taxed in the other State but only so much of them as is
      attributable to:·</p>
                    <p>a) that permanent establishment; or</p>
                    <p>b) sales in that other State of goods or merchandise of the same or similar kind as
      those sold through that permanent establishment; or</p>
                    <p>c) other business activities carried on in that other State of the same or similar
      kind as those effected through that permanent establishment.</p>
                    <p>The provisions of sub-paragraphs b) and c) shall not apply if the enterprise shows
      that such sales or activities could not reasonably have been undertaken by that permanent
      establishment.</p>
                    <p>2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting
      State carries on business in the other Contracting State through a permanent establishment
      situated therein, there shall in each Contracting State be attributed to that permanent
      establishment the profits which it might be expected to make if it were a distinct and
      separate enterprise engaged in the same or similar activities under the same or similar
      conditions and dealing wholly independently with the enterprise of which it is a permanent
      establishment.</p>
                    <p>3. In determining the profits of a permanent establishment, there shall be allowed as
      deductions expenses which are incurred for the purposes of the permanent establishment,
      including executive and general administrative expenses so incurred, whether in the State in
      which the permanent establishment is situated or elsewhere.</p>
                    <p>4. Insofar as it has been customary in a Contracting State to determine the profits to
      be attributed to a permanent establishment on the basis of an apportionment of the total
      profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that
      Contracting State from determining the profits to be taxed by such an apportionment as may be
      customary. The method of apportionment adopted shall, however, be such that the result shall
      be in accordance with the principles contained in this Article.</p>
                    <p>5. No profits shall be attributed to a permanent establishment by reason of the mere
      purchase by that permanent establishment of goods or merchandise for the
      enterprise.</p>
                    <p>6. For the purposes of the preceding paragraphs, the profits to be attributed to the
      permanent establishment shall be determined by the same method year by year unless there is
      good and sufficient reason to the contrary.</p>
                    <p>7. Where profits include items of income which are dealt with separately in other
      Articles of this Convention, then the provisions of those Articles shall not be affected by
      the provisions of this Article.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_2" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1993/96#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_8">
                <num>Article 8</num>
                <heading>Shipping and air transport</heading>
                <content>
                    <p>1. Profits 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. 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>
            <tblock class="noteEditorial" eId="note_3" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1993/96#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_9">
                <num>Article 9</num>
                <heading>Associated enterprises</heading>
                <content>
                    <p>1. Where</p>
                    <p>a) an enterprise of a Contracting State participates directly or indirectly in the
      management, control or capital of an enterprise of the other Contracting State, or</p>
                    <p>b) the same persons participate directly or indirectly in the management, control or
      capital of an enterprise of a Contracting State and an enterprise of the other Contracting
      State,</p>
                    <p>and in either case conditions are made or imposed between the two enterprises in their
      commercial or financial relations which differ from those which would be made between
      independent enterprises, then any profits which would, but for those conditions, have accrued
      to one of the enterprises, but, by reason of those conditions, have not so accrued, may be
      included in the profits of that enterprise and taxed accordingly.</p>
                    <p>2. Where a Contracting State includes in the profits of an enterprise of that State –
      and taxes accordingly – profits on which an enterprise of the other Contracting State has been
      charged to tax in that other State and the profits so included are 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_10">
                <num>Article 10</num>
                <heading>Dividends</heading>
                <content>
                    <p>1. Dividends paid by a company which is a resident of a Contracting State to a
      resident of the other Contracting State may be taxed in that other State. 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 25 per cent of the capital of
      the company paying the dividends;</p>
                    <p>b) 15 per cent of the gross amount of the dividends in all other cases.</p>
                    <p>2. However, as long as an individual resident in Finland is entitled to a tax credit
      in respect of dividends paid by a company resident in Finland, the following provisions of
      this paragraph shall apply in Finland instead of the provisions of paragraph 1:</p>
                    <p>a) Dividends paid by a company which is a resident of Finland to a resident of Estonia
      who is the beneficial owner of the dividends shall be exempt from Finnish tax on
      dividends.</p>
                    <p>b) Notwithstanding the provisions of subparagraph a), where the recipient is an
      individual or a body of persons (other than a company which controls directly at least 10
      percent of the voting power in the company paying the dividends), such dividends may also be
      taxed in Finland and according to Finnish law, but if the recipient is the beneficial owner of
      the dividends the tax so charged shall not exceed 5 per cent of the gross amount of the
      dividends.</p>
                    <p>3. The competent authorities of the Contracting States may by mutual agreement settle
      the mode of application of the provisions of paragraphs I and 2. The provisions of those
      paragraphs shall not affect the taxation of the company in respect of the profits out of which
      the dividends are paid.</p>
                    <p>4. The term " dividends" as used in this Article means income from shares, or other
      rights, not being debt-claims, participating in profits, as well as income from other
      corporate rights which is subjected to the same taxation treatment as income from shares by
      the laws of the State of which the company making the distribution is a resident.</p>
                    <p>5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      dividends, being a resident of a Contracting State, carries on business in the other
      Contracting State of which the company paying the dividends is a resident, through a permanent
      establishment situated therein, or performs in that other State independent personal services
      from a fixed base situated therein, and the holding in respect of which the dividends are paid
      is effectively connected with such permanent establishment or fixed base. In such case the
      provisions of Article 7 or Article 14, as the case may be, shall apply.</p>
                    <p>6. Where a company which is a resident of a Contracting State derives profits or
      income from the other Contracting State, that other State may not impose any tax on the
      dividends paid by the company, except insofar as such dividends are paid to a resident of that
      other State or insofar as the holding in respect of which the dividends are paid is
      effectively connected with a permanent establishment or a fixed base situated in that other
      State, nor subject the company's undistributed profits to a tax on the company's undistributed
      profits, even if the dividends paid or the undistributed profits consist wholly or partly of
      profits or income arising in such other State.</p>
                </content>
            </article>
            <article eId="art_11">
                <num>Article 11</num>
                <heading>Interest</heading>
                <content>
                    <p>1. Interest arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such interest may also be taxed in the Contracting State in which it
      arises and according to the laws of that State, but if the recipient is the beneficial owner
      of the interest the tax so charged shall not exceed 10 per cent of the gross amount of the
      interest. The competent authorities of the Contracting States may by mutual agreement settle
      the mode of application of this limitation.</p>
                    <p>3. Notwithstanding the provisions of paragraphs 1 and 2,</p>
                    <p>a) interest arising in Estonia shall be taxable only in Finland if the interest is
      paid to:</p>
                    <p>(i) the State of Finland, or a local authority or a statutory body thereof;</p>
                    <p>(ii) the Bank of Finland;</p>
                    <p>(iii) the Finnish Fund for Industrial Cooperation Ltd (FINNFUND) or the Finnish Export
      Credit Ltd; or</p>
                    <p>(iv) any other institution, similar to those mentioned in subdivision (iii), as may be
      agreed from time to time between the competent authorities of the Contracting
      States;</p>
                    <p>b) interest arising in Finland shall be taxable only in Estonia if the interest is
      paid to:</p>
                    <p>(i) the State of Estonia, or a local authority or a statutory body thereof;</p>
                    <p>(ii) the Bank of Estonia;</p>
                    <p>(iii) any organisation established in the State of Estonia after the date of signature
      of this Convention and which is of a similar nature as any organisation established in Finland
      and referred to in subdivision (iii) of subparagraph a) (the competent authorities of the
      Contracting States shall by mutual agreement determine whether such organisations are of a
      similar nature); or</p>
                    <p>(iv) any institution similar to any of those referred to in subdivision (iv) of
      sub-paragraph a), as may be agreed from time to time between the competent authorities of the
      Contracting States;</p>
                    <p>c) interest arising in a Contracting State on a loan guaranteed by any of the bodies
      mentioned or referred to in sub-paragraph a) or sub-paragraph b) and paid to a resident of the
      other Contracting State shall be taxable only in that other State;</p>
                    <p>d) interest arising in a Contracting State shall be taxable only in the other
      Contracting State if:</p>
                    <p>(i) the recipient is a resident of that other State, and</p>
                    <p>(ii) such recipient is an enterprise of that other State and is the beneficial owner
      of the interest, and</p>
                    <p>(iii) the interest is paid with respect to indebtedness arising on the sale on credit,
      by that enterprise, of any merchandise or industrial, commercial or scientific equipment to an
      enterprise of the first-mentioned State, except where the sale or indebtedness is between
      related persons.</p>
                    <p>4. The term "interest" as used in this Article means income from debt-claims of every
      kind, whether or not secured by mortgage, 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>5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      interest, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the interest arises, through a permanent establishment situated
      therein, or performs in that other State independent personal services from a fixed base
      situated therein, and the debt-claim in respect of which the interest is paid is effectively
      connected with such permanent establishment or fixed base. In such case the provisions of
      Article 7 or Article 14, as the case may be, shall apply.</p>
                    <p>6. Interest shall be deemed to arise in a Contracting State when the payer is a
      resident of that State. Where, however, the person paying the interest, whether he is a
      resident of a Contracting State or not, has in a Contracting State a permanent establishment
      or a fixed base in connection with which the indebtedness on which the interest is paid was
      incurred, and such interest is borne by such permanent establishment or fixed base, then such
      interest shall be deemed to arise in the State in which the permanent establishment or fixed
      base is situated.</p>
                    <p>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 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>
            <tblock class="noteEditorial" eId="note_4" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1993/96#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_12">
                <num>Article 12</num>
                <heading>Royalties</heading>
                <content>
                    <p>1. Royalties arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such royalties may also be taxed in the Contracting State in which they
      arise and according to the laws of that State, but if the recipient is the beneficial owner of
      the royalties, the tax so charged shall not exceed:</p>
                    <p>a) 5 per cent of the gross amount of royalties paid for the use of industrial,
      commercial or scientific equipment;</p>
                    <p>b) 10 per cent of the gross amount of the royalties in all other cases.</p>
                    <p>The competent authorities of the Contracting States may by mutual agreement settle the
      mode of application of these limitations.</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 television or radio
      broadcasting, 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>4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      royalties, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the royalties arise, through a permanent establishment situated
      therein, or performs in that other State independent personal services from a fixed base
      situated therein, and the right or property in respect of which the royalties are paid is
      effectively connected with such permanent establishment or fixed base. In such case the
      provisions of Article 7 or Article 14, as the case may be, shall apply.</p>
                    <p>5. Royalties shall be deemed to arise in a Contracting State when the payer is a
      resident of that State. Where, however, the person paying the royalties, whether he is a
      resident of a Contracting State or not, has in a Contracting State a permanent establishment
      or a fixed base in connection with which the liability to pay the royalties was incurred, and
      such royalties are borne by such permanent establishment or fixed base, then such royalties
      shall be deemed to arise in the State in which the permanent establishment or fixed base is
      situated.</p>
                    <p>6. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the royalties, having
      regard to the use, right or information for which they are paid, exceeds the amount which
      would have been agreed upon by the payer and the beneficial owner in the absence of such
      relationship, the provisions of this Article shall apply only to the last-mentioned amount. In
      such case, the excess part of the payments shall remain taxable according to the laws of each
      Contracting State, due regard being had to the other provisions of this Convention.</p>
                    <p>7. If in any convention for the avoidance of double taxation concluded by Estonia with
      a third State, being a member of the Organisation for Economic Co-operation and Development
      (OECD) at the date of signature of this Convention, Estonia after that date would agree to
      exclude any kind of rights or property from the definition contained in paragraph 3 or exempt
      royalties arising in Estonia from Estonian tax on royalties or to limit the rates of tax
      provided in paragraph 2, such definition or exemption or lower rate shall automatically apply
      as if it had been specified in paragraph 3 or paragraph 2, respectively.</p>
                </content>
            </article>
            <p>
                <authorialNote>
                    <p>
                        See
                        <a href="/akn/fi/doc/treaty/2016/55">SopS 55/2016</a>
                              regarding the application of paragraphs 2 and 3. Unofficial
                        <a href="/akn/fi/doc/tax-treaty-consolidated/1993/92/statute">translation</a>
                              of Sops 55/2016 at the end of this document.
                    </p>
                </authorialNote>
            </p>
            <tblock class="noteEditorial" eId="note_5" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1993/96#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_13">
                <num>Article 13</num>
                <heading>Capital gains</heading>
                <content>
                    <p>1. Gains derived by a resident of a Contracting State from the alienation of immovable
      property referred to in paragraph 2 of Article 6 and situated in the other Contracting State
      or shares in a company the assets of which consist mainly of such property may be taxed in
      that other State.</p>
                    <p>2. 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>3. Gains derived by an enterprise of a Contracting State from the alienation of ships
      or aircraft operated in international traffic or movable property pertaining to the operation
      of such ships or aircraft, shall be taxable only in that State.</p>
                    <p>4. 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 Contr1cting State of which
      the alienator is a resident.</p>
                </content>
            </article>
            <article eId="art_14">
                <num>Article 14</num>
                <heading>Independent personal services</heading>
                <content>
                    <p>1. Income derived by 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. If he has such a fixed base, the income
      may be taxed in that other State, but only so much of the income as is attributable to that
      fixed base. For this purpose, where an individual who is a resident of a Contracting State
      stays in the other Contracting State for a period or periods exceeding in the aggregate 183
      days in any twelve-month period commencing or ending in the tax year concerned, he shall be
      deemed to have a fixed base regularly available to him in that other State and the income that
      is derived from his activities referred to above that are performed in that other State shall
      be attributable to that fixed base.</p>
                    <p>2. The term "professional services" includes especially independent scientific,
      literary, artistic, educational or teaching activities as well as the independent activities
      of physicians, lawyers, engineers, architects, dentists and accountants.</p>
                </content>
            </article>
            <article eId="art_15">
                <num>Article 15</num>
                <heading>Dependent personal services</heading>
                <content>
                    <p>1. Subject to the provisions of Articles 16, 18 and 19, 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 any twelve-month period commencing or ending in the tax year
      concerned, and</p>
                    <p>b) the remuneration is paid by, or on behalf of, an employer who is not a resident of
      the other State, and</p>
                    <p>c) the remuneration is not borne by a permanent establishment or a fixed base which
      the employer has in the other State.</p>
                    <p>3. Notwithstanding the preceding provisions of this Article, remuneration derived in
      respect of an employment exercised aboard a ship or aircraft operated in international traffic
      by a resident of a Contracting State, may be taxed in that State.</p>
                </content>
            </article>
            <tblock class="noteEditorial" eId="note_6" finlex:outline="huomautus">
                <p>
                    See also
                    <a href="/akn/fi/doc/tax-treaty-consolidated/1993/96#protocol">Protocol</a>
                          to this Convention.
                </p>
            </tblock>
            <article eId="art_16">
                <num>Article 16</num>
                <heading>Directors' fees</heading>
                <content>
                    <p>Directors' fees and other similar payments derived by a resident of a Contracting
      State in his capacity as a member of the board of directors or any other similar organ of a
      company which is a resident of the other Contracting State may be taxed in that other
      State.</p>
                </content>
            </article>
            <article eId="art_17">
                <num>Article 17</num>
                <heading>Artistes and sportsmen</heading>
                <content>
                    <p>1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident
      of a Contracting State as an entertainer, such as a theatre, motion picture, radio or
      television artiste, or a musician, or as a sportsman, from his personal activities as such
      exercised in the other Contracting State, may be taxed in that other State.</p>
                    <p>2. Where income in respect of personal activities exercised by an entertainer or a
      sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to
      another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be
      taxed in the Contracting State in which the activities of the entertainer or sportsman are
      exercised.</p>
                    <p>3. The provisions of paragraphs I and 2 shall not apply to income derived from
      activities exercised in a Contracting State by an entertainer or a sportsman if the visit to
      that State is wholly or mainly supported by public funds of the other Contracting State or a
      local authority thereof. In such case, the income shall be taxable in accordance with the
      provisions of Article 7, Article 14 or Article 15, as the case may be.</p>
                </content>
            </article>
            <article eId="art_18">
                <num>Article 18</num>
                <heading>Pensions, annuities and similar payments</heading>
                <content>
                    <p>1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar
      remuneration in respect of past employment and annuities paid to a resident of a Contracting
      State shall be taxable only in that State.</p>
                    <p>2. Notwithstanding the provisions of paragraphs 1 and 3, and subject to the provisions
      of paragraph 2 of Article 19,</p>
                    <p>a) pensions paid and other benefits, whether periodic or lump-sum compensation,
      granted under the social security legislation of a Contracting State or under any public
      scheme organised by a Contracting State for social welfare purposes shall be taxable only in
      that State;</p>
                    <p>b) annuities arising in a Contracting State and paid to a resident of the other
      Contracting State shall be exempt from tax in that other State to the extent that they would
      be exempt from tax if received by a resident of the first-mentioned State.</p>
                    <p>3. Notwithstanding the provisions of paragraph 1, in the case of an individual who was
      a resident of a Contracting State and has become a resident of the other Contracting State,
      pensions, annuities and other similar remuneration paid to such individual and arising in the
      first-mentioned State may be taxed in that State according to the laws of that State, but the
      tax so charged shall not exceed 15 per cent of the gross amount of the payment. The provisions
      of this paragraph shall not apply to such individual if he is a stateless person or a national
      of the other Contracting State without also being a national of the first-mentioned
      Contracting State.</p>
                    <p>4. The term "annuity" as used in this Article means a stated sum payable periodically
      at stated times during life, or during a specified or ascertainable period of time, under an
      obligation to make the payments in return for adequate and full consideration in money or
      money's worth (other than services rendered).</p>
                </content>
            </article>
            <article eId="art_19">
                <num>Article 19</num>
                <heading>Government service</heading>
                <content>
                    <p>1. a) Remuneration, other than a pension, paid by a Contracting State, or a local
      authority or a statutory body thereof, to an individual in respect of dependent personal
      services rendered to that State, authority or body shall be taxable only in that
      State.</p>
                    <p>b) However, such remuneration shall be taxable only in the Contracting State of which
      the individual is a resident if the services are rendered in that State and the
      individual:</p>
                    <p>(i) is a national of that State; or</p>
                    <p>(ii) did not become a resident of that State solely for the purpose of rendering the
      services.</p>
                    <p>2. a) Any pension paid by, or out of funds created by, a Contracting State, or a local
      authority or a statutory body thereof, to an individual in respect of services rendered to
      that State, authority or body shall be taxable only in that State.</p>
                    <p>b) However, such pension shall be taxable only in the Contracting State of which the
      individual is a resident if he is a national of that State.</p>
                    <p>3. The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions
      in respect of services rendered in connection with a business carried on by a Contracting
      State, or a local authority or a statutory body thereof.</p>
                </content>
            </article>
            <article eId="art_20">
                <num>Article 20</num>
                <heading>Students</heading>
                <content>
                    <p>Payments which a student, or an apprentice or trainee, who is or was immediately
      before visiting a Contracting State a resident of the other Contracting State and who is
      present in the first-mentioned State solely for the purpose of his education or training
      receives for the purpose of his maintenance, education or training shall not be taxed in that
      State, provided that such payments arise from sources outside that State.</p>
                </content>
            </article>
            <article eId="art_21">
                <num>Article 21</num>
                <heading>Other income</heading>
                <content>
                    <p>1. Items of income of a resident of a Contracting State not dealt with in the
      foregoing Articles of this Convention shall be taxable only in that State. However, such items
      of income, 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 6, if the recipient of such income,
      being a resident of a Contracting State, carries on business in the other Contracting State
      through a permanent establishment situated therein, or performs in that other State
      independent personal services from a fixed base situated therein, and the right or property in
      respect of which the income is paid is effectively connected with such permanent establishment
      or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be,
      shall apply.</p>
                </content>
            </article>
            <article eId="art_22">
                <num>Article 22</num>
                <heading>Capital</heading>
                <content>
                    <p>1. Capital represented by immovable property referred to in paragraph 2 of Article 6,
      owned by a resident of a Contracting State and situated in the other Contracting State, or by
      shares in a company the assets of which consist mainly of such property may be taxed in that
      other State.</p>
                    <p>2. Capital represented by movable property forming part of the business property of a
      permanent establishment which an enterprise of a Contracting State has in the other
      Contracting State or by movable property pertaining to a fixed base available to a resident of
      a Contracting State in the other Contracting State for the purpose of performing independent
      personal services, may be taxed in that other State.</p>
                    <p>3. Capital represented by ships and aircraft operated in international traffic by an
      enterprise of a Contracting State, and by movable property pertaining to the operation of such
      ships and aircraft, shall be taxable only in that State.</p>
                    <p>4. All other elements of capital of a resident of a Contracting State shall be taxable
      only in that State.</p>
                </content>
            </article>
            <article eId="art_23">
                <num>Article 23</num>
                <heading>Elimination of double taxation</heading>
                <content>
                    <p>1. In Finland double taxation shall be eliminated as follows:</p>
                    <p>a) Where a resident of Finland derives income or owns elements of capital which, in
      accordance with the provisions of this Convention, may be taxed in Estonia, Finland shall,
      subject to the provision of subparagraph b), allow:</p>
                    <p>(i) as a deduction from the tax on the income of that person, an amount equal to the
      tax on income paid in Estonia;</p>
                    <p>(ii) as a deduction from the tax on the capital of that person, an amount equal to the
      tax on elements of capital paid in Estonia.</p>
                    <p>Such deduction in either case shall not, however, exceed that part of the tax on the
      income or on the capital, as computed before the deduction is given, which is attributable, as
      the case may be, to the income or to the same elements of capital, which may be taxed in
      Estonia.</p>
                    <p>b) Dividends paid by a company which is a resident of Estonia to a company which is a
      resident of Finland and controls directly at least 10 per cent of the voting power in the
      company paying the dividends shall be exempt from Finnish tax.</p>
                    <p>c) Notwithstanding any other provision of this Convention, an individual who is a
      resident of Estonia and under Finnish taxation law with respect to the Finnish taxes referred
      to in Article 2 also is regarded as resident in Finland may be taxed in Finland. However,
      Finland shall allow any Estonian tax paid on income or on capital 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 provision of the Convention income derived or capital
      owned by a resident of Finland is exempt from tax in Finland, Finland may nevertheless, in
      calculating the amount of tax on the remaining income or capital of such person, take into
      account the exempted income or capital.</p>
                    <p>e) For the purposes of sub-paragraph a), the term "tax on income paid in Estonia"
      shall be deemed to include Estonian income tax which would have been paid but for any
      time-limited exemption or reduction of tax granted under incentive provisions contained in
      Estonian laws designed to promote economic development to the extent that such tax that would
      have been paid relates to profits other than profits from activities in the financial sector
      and that no more than 25 per cent of such profits consist of interest and gains from the
      alienation of shares and bonds or consist of profits derived from third States.</p>
                    <p>f) The provisions of sub-paragraph e) shall apply for the first ten years for which
      the Convention is effective. However, the competent authorities of the Contracting States may
      consult each other in order to determine whether such period shall be extended.</p>
                    <p>g) For the purposes of sub-paragraph a), tax that is paid in Estonia and that could
      not be imposed according to the provisions of this Convention but for the provisions of
      subparagraph b) of paragraph 2, shall be deemed not to have been paid in Estonia.</p>
                    <p>2. In Estonia double taxation shall be eliminated as follows:</p>
                    <p>a) Where a resident of Estonia derives income or owns capital which in accordance with
      this Convention, may be taxed in Finland, unless a more favourable treatment is provided in
      its domestic law, Estonia shall allow:</p>
                    <p>(i) as a deduction from the tax on the income of that resident, an amount equal to the
      income tax paid thereon in Finland;</p>
                    <p>(ii) as a deduction from the tax on the capital of that resident, an amount equal to
      the capital tax paid thereon in Finland.</p>
                    <p>Such deduction in either case shall not, however, exceed that part of the income or
      capital tax in Estonia, as computed before the deduction is given, which is attributable, as
      the case may be, to the income or the capital which may be taxed in Finland.</p>
                    <p>b) Notwithstanding any other provision of this Convention, an individual who is a
      resident of Finland and under Estonian taxation law with respect to the Estonian taxes
      referred to in Article 2 also is regarded as resident in Estonia may be taxed in Estonia.
      However, Estonia shall allow any Finnish tax paid on income or on capital as a deduction from
      Estonian tax in accordance with the provisions of sub-paragraph a). The provisions of this
      sub-paragraph shall apply only to nationals of Estonia.</p>
                    <p>c) For the purpose of sub-paragraph a), where a company that is a resident of Estonia
      receives a dividend from a company that is a resident of Finland in which it owns at least 10
      per cent of its shares having full voting rights, the tax paid in Finland shall include not
      only the tax paid on the dividend but also the tax paid on the underlying profits of the
      company out of which the dividend was paid.</p>
                    <p>d) For the purposes of sub-paragraph a), tax that is paid in Finland and that could
      not be imposed according to the provisions of this Convention but for the provisions of
      subparagraph c) of paragraph 1, shall be deemed not to have been paid in Finland.</p>
                </content>
            </article>
            <article eId="art_24">
                <num>Article 24</num>
                <heading>Non-discrimination</heading>
                <content>
                    <p>1. Nationals of a Contracting State shall not be subjected in the other Contracting
      State to any taxation or any requirement connected therewith, which is other or more
      burdensome than the taxation and connected requirements to which nationals of that other State
      in the same circumstances, in particular with respect to residence, are or may be subjected.
      This provision shall, notwithstanding the provisions of Article 1, also apply to persons who
      are not residents of one or both of the Contracting States.</p>
                    <p>2. Stateless persons who are residents of a Contracting State shall not be subjected
      in either Contracting State to any taxation or any requirement connected therewith which is
      other or more burdensome than the taxation and connected requirements to which nationals of
      the State concerned in the same circumstances, in particular with respect to residence, are or
      may be subjected.</p>
                    <p>3. The taxation on a permanent establishment which an enterprise of a Contracting
      State has in the other Contracting State shall not be less favourably levied in that other
      State than the taxation levied on enterprises of that other State carrying on the same
      activities. This provision shall not be construed as obliging a Contracting State to grant to
      residents of the other Contracting State any personal allowances, reliefs and reductions for
      taxation purposes on account of civil status or family responsibilities which it grants to its
      own residents.</p>
                    <p>4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11,
      or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an
      enterprise of a Contracting State to a resident of the other Contracting State shall, for the
      purpose of determining the taxable profits of such enterprise, be deductible under the same
      conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any
      debts of an enterprise of a Contracting State to a resident of the other Contracting State
      shall, for the purpose of determining the taxable capital of such enterprise, be deductible
      under the same conditions as if they had been contracted to a resident of the first-mentioned
      State.</p>
                    <p>5. Enterprises of a Contracting State, the capital of which is wholly or partly owned
      or controlled, directly or indirectly, by one or more residents of the other Contracting
      State, shall not be subjected in the first-mentioned State to any taxation or any requirement
      connected therewith which is other or more burdensome than the taxation and connected
      requirements to which other similar enterprises of the first-mentioned State are or may be
      subjected.</p>
                    <p>6. The provisions of this Article shall, notwithstanding the provisions of Article 2,
      apply to taxes of every kind and description.</p>
                </content>
            </article>
            <article eId="art_25">
                <num>Article 25</num>
                <heading>Mutual agreement procedure</heading>
                <content>
                    <p>
                        <embeddedStructure class="mli-replaced">
                            <p>
                                <authorialNote>
                                    <p>1. [The first sentence of paragraph 1 of Article 25 of this Convention is REPLACED
        by the first sentence of paragraph 1 of Article 16 of the MLI]</p>
                                </authorialNote>
                            </p>
                            <p>[Where a person considers that the actions of one or both of the Contracting States
        result or will result for him in taxation not in accordance with the provisions of this
        Convention, he may, irrespective of the remedies provided by the domestic law of those
        States, present his case to the competent authority of the Contracting State of which he is
        a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting
        State of which he is a national.] The case must be presented within three years from the first notification of the
      action resulting in taxation not in accordance with the provisions of the
      Convention.</p>
                        </embeddedStructure>
                    </p>
                    <p>
                        <embeddedStructure class="mli-replacement">
                            <p>
                                <authorialNote>
                                    <p>
                                        The following first sentence of paragraph 1 of Article 16 of the MLI replaces
        the first sentence of paragraph 1 of Article 25 of this Convention:
                                        <authorialNote marker="2" placement="bottom">
                                            <p>In accordance with paragraphs 1, 3 and 7 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 2023;</p>
                                            <p>and,</p>
                                            <p>In accordance with paragraphs 1, 3 and 7 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 Republic of Estonia:</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 Estonia, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2023.</p>
                                        </authorialNote>
                                    </p>
                                </authorialNote>
                            </p>
                            <article>
                                <num>ARTICLE 16 OF THE MLI – MUTUAL AGREEMENT PROCEDURE</num>
                                <content>
                                    <p>
                                        Where a person considers that the actions of one or both of the
            [
                                        <i>Contracting States</i>
                                        ] result or will result for that person in
          taxation not in accordance with the provisions of [
                                        <i>this
          Convention</i>
                                        ], that person may, irrespective of the remedies provided by the
          domestic law of those [
                                        <i>Contracting States</i>
                                        ], present the case to the
          competent authority of either [
                                        <i>Contracting State</i>
                                        ].
                                    </p>
                                </content>
                            </article>
                        </embeddedStructure>
                    </p>
                    <p>2. The competent authority shall endeavour, if the objection appears to it to be
      justified and if it is not itself able to arrive at a satisfactory solution, to resolve the
      case by mutual agreement with the competent authority of the other Contracting State, with a
      view to the avoidance of taxation which is not in accordance with the Convention. In the event
      the competent authorities reach an agreement, refund or credit of taxes shall be allowed by
      the Contracting States in accordance with such agreement. Any agreement reached shall be
      implemented notwithstanding any time limits in the domestic law of the Contracting
      States.</p>
                    <p>3. The competent authorities of the Contracting States shall endeavour to resolve by
      mutual agreement any difficulties or doubts arising as to the interpretation or application of
      the 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 precedidg 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="art_26">
                <num>Article 26</num>
                <heading>Exchange of information</heading>
                <content>
                    <p>1. The competent authorities of the Contracting States shall exchange such information
      as is necessary for carrying out the provisions of this Convention or of the domestic laws of
      the Contracting States concerning taxes covered by the Convention insofar as the taxation
      thereunder is not contrary to the Convention. The exchange of information is not restricted by
      Article 1. Any information received by a Contracting State shall be treated as secret in the
      same manner as information obtained under the domestic laws of that State and shall be
      disclosed only to persons or authorities (including courts and administrative bodies) involved
      in the assessment or collection of, the enforcement or prosecution in respect of, or the
      determination of appeals in relation to, the taxes covered by the Convention. Such persons or
      authorities shall use the information only for such purposes. They may disclose the
      information in public court proceedings or in judicial decisions.</p>
                    <p>2. In no case shall the provisions of paragraph 1 be construed so as to impose on a
      Contracting State the obligation:</p>
                    <p>a) to carry out administrative measures at variance with the laws and administrative
      practice of that or of the other Contracting State;</p>
                    <p>b) to supply information which is not obtainable under the laws or in the normal
      course of the administration of that or of the other Contracting State;</p>
                    <p>c) to supply information which would disclose any trade, business, industrial,
      commercial or professional secret or trade process, or information, the disclosure of which
      would be contrary to public policy (ordre public).</p>
                </content>
            </article>
            <article eId="art_27">
                <num>Article 27</num>
                <heading>Assistance in collection</heading>
                <content>
                    <p>1. The Contracting States undertake to lend assistance to each other in the collection
      of the taxes owed by a taxpayer to the extent that the amount thereof has been finally
      determined according to the laws of the Contracting State making the request for
      assistance.</p>
                    <p>2. In the case of a request by a Contracting State for the collection of taxes which
      has been accepted for collection by the other Contracting State, such taxes shall be collected
      by that other State in accordance with the laws applicable to the collection of its own taxes
      and as if the taxes to be so collected were its own taxes.</p>
                    <p>3. Any request for collection by a Contracting State shall be accompanied by such
      certificate as is required by the laws of that State to establish that the taxes owed by the
      taxpayer have been finally determined.</p>
                    <p>4. Where the tax claim of a Contracting State has not been finally determined by
      reason of it being subject to appeal or other proceedings, that State may, in order to protect
      its revenues, request the other Contracting State to take such interim measures for
      conservancy on its behalf as are available to the other State under the laws of that other
      State. If such request is accepted by the other State, such interim measures shall be taken by
      that other State as if the taxes owed to the first-mentioned State were the own taxes of that
      other State.</p>
                    <p>5. A request under paragraph 3 or paragraph 4 shall only be made by a Contracting
      State to the extent that sufficient property of the taxpayer owing the taxes is not available
      in that State for recovery of the taxes owed.</p>
                    <p>6. The Contracting State in which tax is recovered in accordance with the provisions
      of this Article shall forthwith remit to the Contracting State on behalf of which the tax was
      collected the amount so recovered less, where appropriate, the amount of extraordinary costs
      referred to in sub-paragraph b) of paragraph 7.</p>
                    <p>7. It is understood that unless otherwise agreed by the competent authorities of both
      Contracting States,</p>
                    <p>a) ordinary costs incurred by a Contracting State in providing assistance shall be
      borne by that State,</p>
                    <p>b) extraordinary costs incurred by a Contracting State in providing assistance shall
      be borne by the other State and shall be payable regardless of the amount collected on its
      behalf by that other State.</p>
                    <p>As soon as a Contracting State anticipates that extraordinary costs may be incurred,
      it shall so advise the other Contracting State and indicate the estimated amount of such
      costs.</p>
                    <p>8. In this Article, the term "taxes" means the taxes to which the Convention applies
      and includes any interest and penalties relating thereto.</p>
                </content>
            </article>
            <article eId="art_28">
                <num>Article 28</num>
                <heading>Members of diplomatic missions and consular posts</heading>
                <content>
                    <p>Nothing in this Convention shall affect the fiscal privileges of members of diplomatic
      missions or consular posts under the general rules of international law or under the
      provisions of special agreements.</p>
                </content>
            </article>
            <p>
                <embeddedStructure class="mli-replacement">
                    <p>
                        <authorialNote>
                            <p>
                                The following paragraph 1 of Article 7 of the MLI applies and supersedes the
      provisions of this Convention:
                                <authorialNote marker="3" placement="bottom">
                                    <p>In accordance with paragraphs 1, 3 and 7 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 2023;</p>
                                    <p>and,</p>
                                    <p>In accordance with paragraphs 1, 3 and 7 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
          Republic of Estonia:</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 Estonia, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2023.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision)</num>
                        <content>
                            <p>
                                Notwithstanding any provisions of [
                                <i>the Convention</i>
                                ], a benefit
        under [
                                <i>the Convention</i>
                                ] shall not be granted in respect of an item of
        income or capital if it is reasonable to conclude, having regard to all relevant facts and
        circumstances, that obtaining that benefit was one of the principal purposes of any
        arrangement or transaction that resulted directly or indirectly in that benefit, unless it
        is established that granting that benefit in these circumstances would be in accordance with
        the object and purpose of the relevant provisions of [
                                <i>the
        Convention</i>
                                ].
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <article eId="art_29">
                <num>Article 29</num>
                <heading>Entry into force</heading>
                <content>
                    <p>1. The Governments of the Contracting States shall notify each other that the
      constitutional requirements for the entry into force of this Convention have been complied
      with.</p>
                    <p>2. The Convention shall enter into force thirty days after the date of the later of
      the notifications referred to in paragraph 1 and its provisions shall have effect in both
      Contracting States:</p>
                    <p>a) in respect of taxes withheld at source, on income derived on or after I January in
      the calendar year next following the year in which the Convention enters into
      force;</p>
                    <p>b) in respect of other taxes on income, and taxes on capital, for taxes chargeable for
      any tax year beginning on or after I January in the calendar year next following the year in
      which the Convention enters into force.</p>
                </content>
            </article>
            <article eId="art_30">
                <num>Article 30</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 in writing at least six months before the end of any calendar year. In such
      event, the Convention shall cease to have effect in both Contracting States:</p>
                    <p>a) in respect of taxes withheld at source, on income derived on or after 1 January in
      the calendar year next following the year in which the notice is given;</p>
                    <p>b) in respect of other taxes on income, and taxes on capital, for taxes chargeable for
      any tax year beginning on or after 1 January in the calendar year next following the year in
      which the notice is given.</p>
                    <p>In witness whereof the undersigned, duly authorised thereto, have signed this
      Convention.</p>
                    <p>Done in duplicate at Helsinki this 23rd day of March 1993, in the English
      language.</p>
                </content>
            </article>
            <hcontainer name="attachments">
                <hcontainer eId="protocol" name="attachment">
                    <heading>Protocol</heading>
                    <content>
                        <p>At the signing today of the Convention between the Republic of Finland and the
      Republic of Estonia for the avoidance of double taxation and the prevention of fiscal evasion
      with respect to taxes on income and on capital (hereinafter referred to as "the Convention"),
      the undersigned have agreed upon the following provisions which shall form an integral part of
      the Convention:</p>
                        <tblock>
                            <num>1. With reference to the provisions of the Convention</num>
                            <p>Where the term "statutory body" appears, it is understood that this term means any
        legal entity of a public character created by the laws of a Contracting State in which no
        person other than the State itself, or a political subdivision or a local authority thereof,
        has an interest.</p>
                        </tblock>
                        <tblock>
                            <num>2. With reference to Article 7, paragraph 3</num>
                            <p>It is understood that expenses to be allowed as deductions by a Contracting State
        include only expenses that are deductible under the domestic laws of that State.</p>
                        </tblock>
                        <tblock>
                            <num>3. With reference to Article 8</num>
                            <p>It is understood that "profits of an enterprise of a Contracting State from the
        operation of ships in international traffic" shall be interpreted according to paragraphs 7
        to 14 of the Commentary on Article 8 of the OECD Model Tax Convention on Income and on
        Capital (1992) and does not, in any event, include the profits from the operation or
        ownership of docks, warehouses, terminal facilities, stevedoring equipment or other similar
        property located on land, except where these profits are directly related to the operation,
        by the enterprise, of such ships.</p>
                        </tblock>
                        <tblock>
                            <num>4. With reference to Article 11, paragraph 3 d)</num>
                            <p>It is understood that a person is related to another person, where one person, alone
        or together with one or more related persons, has, directly or indirectly, an interest of
        more than 50 per cent in the other person, or where one or more persons, alone or together
        with one or more related persons, have, directly or indirectly, an interest of more than 50
        per cent in the two persons.</p>
                        </tblock>
                        <tblock>
                            <num>5. With reference to Article 12, paragraph 2</num>
                            <p>It is understood that the term "royalties" shall be deemed not to include payments
        for the use of drilling rigs, or similar purpose equipment, used for the exploration for or
        the extraction of hydrocarbons.</p>
                        </tblock>
                        <tblock>
                            <num>6. With reference to Article 12, paragraph 3</num>
                            <p>It is agreed that the income from leasing of industrial, commercial or scientific
        equipment shall be included in the term "royalties" as defined in Article 12, paragraph
        3.</p>
                        </tblock>
                        <tblock>
                            <num>7. With reference to Article 15, paragraph 2</num>
                            <p>The provisions of Article 15, paragraph 2, shall not apply to an employee who is
        hired out. For the purposes of the preceding sentence, an employee who is a resident of a
        Contracting State shall be deemed to be hired out if he is placed at anotner person's
        disposal by a person (the hirer-out) to carry out work in the business of such other person
        (the principal) in the other Contracting State, provided that the principal is a resident
        of, or has a permanent establishment in, that other State, and that the hirer-out neither
        has any responsibility nor bears any risk in respect of the result of the work.</p>
                            <p>In determining whether an employee shall be deemed to be hired out, a comprehensive
        review shall be carried out, with particular reference to whether:</p>
                            <p>a) the overall supervision of the work rests with the principal;</p>
                            <p>b) the work is carried out in a place of work which is at the disposal of the
        principal and for which he has responsibility;</p>
                            <p>c) the remuneration to the hirer-out is computed according to the time spent or with
        reference to any other relationship between the remuneration and the wages received by the
        employee;</p>
                            <p>d) the main part of the tools and materials are supplied by the principal;
        and</p>
                            <p>e) the hirer-out does not decide unilaterally on the number of employees or their
        qualifications.</p>
                            <p>In witness whereof the undersigned, duly authorised thereto, have signed this
        Protocol.</p>
                            <p>Done in duplicate at Helsinki this 23rd day of March 1993, in the English
        language.</p>
                        </tblock>
                    </content>
                </hcontainer>
                <hcontainer name="attachment">
                    <heading>UNOFFICIAL TRANSLATION</heading>
                    <content>
                        <p>
                            <authorialNote>
                                <p>This is unofficial translation of notification SopS 55/2016.</p>
                            </authorialNote>
                        </p>
                        <p>
                            <b>Notification of the Ministry of Finance of an amendment to the
        application of Article 12 of the Convention between the Republic of Finland and the Republic
        of Estonia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with
        Respect to Taxes on Income and on Capital 25.8.2016 </b>
                                  (<a href="/akn/fi/doc/treaty/2016/55">SopsS 55/2016</a>)
                        </p>
                        <p>Article 12(7) of the Convention between the Republic of Finland and the Republic of
      Estonia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect
      to Taxes on Income and on Capital (Finnish Treaty Series 96/1993) provides that if, after the
      date of this Convention, Estonia agrees, in any treaty for the avoidance of double taxation
      concluded between Estonia and a third state that is a member of the Organisation for Economic
      Co-operation and Development (OECD) at the date of signature of this Convention, to exclude
      any right or property from the definition contained in paragraph 3 or exempt royalties arising
      in Estonia from Estonian tax on royalties or limit the rates of tax provided in para-graph 2,
      such definition or exemption or lower rate shall apply automatically as if it had been
      specified in paragraph 2 or 3. Estonia has given notification that it has concluded a treaty
      as referred to above.</p>
                        <p>As of 1 January 2016, the following provisions shall apply in place of Article 12(2)
      and (3) of the Convention between the Republic of Finland and the Republic of Estonia for the
      Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on
      Income and on Capital:</p>
                        <p>2. Royalties shall not be taxed in the Contracting State in which they
      arise.</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, any patent, trade mark, design or model, plan,
      secret formula or process, or for information concerning industrial, commercial or scientific
      experience.</p>
                    </content>
                </hcontainer>
            </hcontainer>
        </mainBody>
    </doc>
</akomaNtoso>
