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        <preface>
            <p>
                <docNumber>79-80/1995</docNumber>
                <docTitle>Agreement between the Republic of Finland and the Czech Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income </docTitle>
            </p>
        </preface>
        <preamble>
            <p>
                <embeddedStructure class="mli-addition">
                    <tblock>
                        <heading>SYNTHESISED TEXT OF THE MLI AND THE AGREEMENT BETWEEN THE REPUBLIC OF FINLAND AND THE CZECH REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME</heading>
                        <p>This document presents the synthesised text for the application of the Agreement
      between the Republic of Finland and the Czech Republic for the avoidance of double taxation
      and the prevention of fiscal evasion with respect to taxes on income signed on 2 December 1994
      (the Agreement), as modified by the Multilateral Convention to Implement Tax Treaty Related
      Measures to Prevent Base Erosion and Profit Shifting signed by the Republic of Finland and the
      Czech Republic on 7 June 2017 (the “MLI”).</p>
                        <p>This document was prepared by the competent authority of Finland and represents its
      understanding of the modifications made to the Agreement by the MLI. In preparing this
      document, the competent authority of Finland consulted with the competent authority of the
      Czech Republic.</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
      Czech Republic to the Depositary upon ratification on 13 May 2020. These MLI positions are
      subject to modifications as provided in the MLI. Modifications made to MLI positions could
      modify the effects of the MLI on the Agreement. The Republic of Finland modified its MLI
      position by withdrawing its reservation made to Article 9 and by making additional
      notifications (consolidated MLI position of the Republic of Finland on 27 June 2023). These
      modifications did not modify the effects of the MLI on the Agreement.</p>
                        <p>The authentic legal texts of the Agreement and the MLI take precedence and remain the
      legal texts applicable.</p>
                        <p>The provisions of the MLI that are applicable with respect to the provisions of the
      Agreement are included in boxes throughout the text of this document in the context of the
      relevant provisions of the Convention. The boxes containing the provisions of the MLI have
      generally been inserted in accordance with the ordering of the provisions of the 2017 OECD
      Model Tax Convention.</p>
                        <p>Changes to the text of the provisions of the MLI have been made to conform the
      terminology used in the MLI to the terminology used in the Agreement (such as “Covered Tax
      Agreement” and “Convention”, “Contracting Jurisdictions” and “Contracting States”), to ease
      the comprehension of the provisions of the MLI. The changes in terminology are intended to
      increase the readability of the document and are not intended to change the substance of the
      provisions of the MLI. Similarly, changes have been made to parts of provisions of the MLI
      that describe existing provisions of the Convention: descriptive language has been replaced by
      legal references of the existing provisions to ease the readability.</p>
                        <p>In all cases, references made to the provisions of the Agreement or to the Agreement
      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 Agreement do not take effect on the same
      dates as the original provisions of the Agreement. Each of provisions of the MLI could take
      effect on different dates, depending on the types of taxes involved (taxes withheld at source
      or other taxes levied) and on the choices made by the Republic of Finland and the Czech
      Republic in their MLI positions.</p>
                        <p>Dates of the deposit of instruments of ratification, acceptance or approval: 25
      February 2019 for the Republic of Finland and 13 May 2020 for Czech Republic.</p>
                        <p>Entry into force of the MLI: 1 June 2019 for the Republic of Finland and 1 September
      2020 for the Czech Republic.</p>
                        <p>This document provides specific information on the dates on or after which each of the
      provisions of the MLI has effect with respect to the Agreement throughout this
      document.</p>
                        <p>
                            <b>References</b>
                        </p>
                        <p>The authentic legal texts of the MLI can be found on the MLI Depositary (OECD)
      webpage:</p>
                        <p>
                            – in English:
                            <a href="http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf">http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf</a>
                                  and
                        </p>
                        <p>
                            – in French:
                            <a href="http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf">http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf</a>
                        </p>
                        <p>
                            The MLI position of the Republic of Finland submitted to the Depositary upon
      acceptance on 25 February 2019, the consolidated MLI position of the Republic of Finland
      submitted to the Depositary on 27 June 2023 and the MLI position of the Czech Republic
      submitted to the Depositary upon ratification on 13 May 2020 can be found on the MLI
      Depositary (OECD) webpage:
                            <a href="http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf">http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf</a>
                        </p>
                        <p>
                            The MLI Matching Database is publicly available on the OECD webpage:
                            <a href="http://www.oecd.org/tax/treaties/mli-matching-database.htm">http://www.oecd.org/tax/treaties/mli-matching-database.htm</a>
                        </p>
                        <p>
                            The Act on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent
      Base Erosion and Profit Shifting is published in Statute Book of Finland 231/2019. Link to
      Finnish language version
                            <a href="https://www.finlex.fi/fi/laki/alkup/2019/20190231">https://www.finlex.fi/fi/laki/alkup/2019/20190231</a>
                                  Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/laki/alkup/2019/20190231">https://www.finlex.fi/sv/laki/alkup/2019/20190231</a>
                        </p>
                        <p>
                            The Government´s Statute on the entry into force of the MLI and the Act and the
      Finnish text (translation) of the MLI is published in the Treaty Series of the Statute Book of
      Finland SopS 21-22/2019. Links to Finnish language versions
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190021">https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190021</a>
                                  and
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190022">https://www.finlex.fi/fi/sopimukset/sopsteksti/2019/20190022</a>
                        </p>
                        <p>
                            Links to Swedish language versions
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190021.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190021.pdf</a>
                                  and
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190022.pdf">https://www.finlex.fi/sv/sopimukset/sopimussarja/2019/fds20190022.pdf</a>
                        </p>
                        <p>
                            The Announcement of the Ministry of Finance on withdrawal of reservation made to
      Article 9 of the MLI and on additional notifications is published in the Treaty Series of the
      Statute Book of Finland SopS 48/2023. Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2023/20230048/20230048_1">https://finlex.fi/fi/sopimukset/sopsteksti/2023/20230048/20230048_1</a>
                                  Link to Swedish language version
                            <a href="https://finlex.fi/sv/sopimukset/sopimussarja/2023/fds20230048.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2023/fds20230048.pdf</a>
                        </p>
                        <p>
                            The Announcement of the Ministry of Finance on the entry into force of the MLI in the
      Czech Republic is published in the Treaty Series of the Statute Book of Finland  SopS 89/2020.
      Link to Finnish language version
                            <a href="https://finlex.fi/fi/sopimukset/sopsteksti/2020/20200089">https://finlex.fi/fi/sopimukset/sopsteksti/2020/20200089</a>.
      Link to Swedish language version
                            <a href="https://www.finlex.fi/sv/sopimukset/sopimussarja/2020/fds20200089.pdf">https://finlex.fi/sv/sopimukset/sopimussarja/2020/fds20200089.pdf</a>
                        </p>
                        <p>
                            The Agreement between the Republic of Finland and the Czech Republic for the avoidance
      of double taxation and the prevention of fiscal evasion with respect to taxes on income signed
      on 2 December 1994 is published in the Treaty Series of the Statute Book of Finland SopS
      80/1995. Link to Finnish language version:
                            <a href="https://www.finlex.fi/fi/sopimukset/sopsteksti/1995/19950080">https://www.finlex.fi/fi/sopimukset/sopsteksti/1995/19950080</a>
                        </p>
                    </tblock>
                </embeddedStructure>
            </p>
            <p class="title">Agreement between the Republic of Finland and the Czech Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income </p>
            <p>The Government of the Republic of Finland and the Government of the Czech
    Republic,</p>
            <p>
                <embeddedStructure class="mli-replaced">
                    <p>
                        <authorialNote>
                            <p>[REPLACED by paragraph 1 of Article 6 of the MLI]</p>
                        </authorialNote>
                    </p>
                    <p>[Desiring to conclude an Agreement for the avoidance of double taxation and the
      prevention of fiscal evasion with respect to taxes on income,]</p>
                </embeddedStructure>
            </p>
            <p>
                <embeddedStructure class="mli-replacement">
                    <p>
                        <authorialNote>
                            <p>
                                The following paragraph 1 of Article 6 of the MLI replaces the text referring to
      an intent to eliminate double taxation in the preamble of this Agreement:
                                <authorialNote marker="1" placement="bottom">
                                    <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
          Article 6 of the MLI has effect with respect to the application of this Agreement by the
          Republic of Finland:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2021;
          and</p>
                                    <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
          levied with respect to taxable periods beginning on or after 1 January 2022;</p>
                                    <p>and,</p>
                                    <p>In accordance with paragraph 1 of Article 35 of the MLI, paragraph 1 of Article 6
          of the MLI has effect with respect to the application of the Agreement by the Czech
          Republic:</p>
                                    <p>a) with respect to taxes withheld at source on amounts paid or credited to
          nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2021;
          and</p>
                                    <p>b) with respect to all other taxes levied by the Czech Republic, for taxes levied
          with respect to taxable periods beginning on or after 1 March 2021.</p>
                                </authorialNote>
                            </p>
                        </authorialNote>
                    </p>
                    <article>
                        <num>ARTICLE 6 OF THE MLI – PURPOSE OF A COVERED TAX AGREEMENT</num>
                        <content>
                            <p>
                                Intending to eliminate double taxation with respect to the taxes covered by
          [
                                <i>this Agreement</i>
                                ] without creating opportunities for non-taxation or
        reduced taxation through tax evasion or avoidance (including through treaty-shopping
        arrangements aimed at obtaining reliefs provided in [
                                <i>the Agreement</i>
                                ]
        for the indirect benefit of residents of third jurisdictions),
                            </p>
                        </content>
                    </article>
                </embeddedStructure>
            </p>
            <p>Have agreed as follows:</p>
        </preamble>
        <mainBody>
            <article eId="art_1">
                <num>Article 1</num>
                <heading>Personal scope</heading>
                <content>
                    <p>This Agreement shall apply to persons who are residents of one or both of the
      Contracting States.</p>
                </content>
            </article>
            <article eId="art_2">
                <num>Article 2</num>
                <heading>Taxes covered</heading>
                <content>
                    <p>1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State
      or of its political subdivisions or local authorities, irrespective of the manner in which
      they are levied.</p>
                    <p>2. There shall be regarded as taxes on income all taxes imposed on total income or on
      elements of income, including taxes on gains from the alienation of movable or immovable
      property, as well as taxes on capital appreciation.</p>
                    <p>3. The existing taxes to which the Agreement 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); and</p>
                    <p>(vi) the tax withheld at source from non-residents' income (rajoitetusti
      verovelvollisen lähdevero; källskatten för begränsat skattskyldig);</p>
                    <p>(hereinafter referred to as "Finnish tax");</p>
                    <p>b) in the Czech Republic:</p>
                    <p>(i) the tax on income of individuals (dan z prijmu fyzickych osob);</p>
                    <p>(ii) the tax on income of legal persons (dan z prijmu pravnickych osob);</p>
                    <p>(hereinafter referred to as "Czech tax").</p>
                    <p>4. The Agreement shall apply also to any identical or substantially similar taxes
      which are imposed after the date of signature of the Agreement in addition to, or in place of,
      the existing taxes. The competent authorities of the Contracting States shall notify each
      other of any significant changes which have been made in their respective taxation
      laws.</p>
                </content>
            </article>
            <article eId="art_3">
                <num>Article 3</num>
                <heading>General definitions</heading>
                <content>
                    <p>1. For the purposes of this Agreement, unless the context otherwise requires:</p>
                    <p>a) the term "Finland" means the Republic of Finland and, when used in a geographical
      sense, means the territory in which the tax laws of the Republic of Finland are
      effective;</p>
                    <p>b) the term "Czech Republic" means the territory in which the tax laws of the Czech
      Republic are effective;</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 the Czech Republic, the Minister of Finance or his authorised
      representative.</p>
                    <p>2. As regards the application of the Agreement 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 Agreement applies.</p>
                </content>
            </article>
            <article eId="art_4">
                <num>Article 4</num>
                <heading>Residence</heading>
                <content>
                    <p>1. For the purposes of this Agreement, the term "resident of a Contracting State" means
      any person who, under the laws of that State, is liable to tax therein by reason of his
      domicile, residence, place of management, place of incorporation (registration) or any other
      criterion of a similar nature. A Contracting State itself, and a political subdivision and a
      local authority and a statutory body thereof, shall be deemed to be a resident of that State.
      The term does not include any person who is liable to tax in that State in respect only of
      income from sources in that State.</p>
                    <p>2. Where by reason of the provisions of paragraph 1 an individual is a resident of
      both Contracting States, then his status shall be determined as follows:</p>
                    <p>a) he shall be deemed to be a resident of the State in which he has a permanent home
      available to him; if he has a permanent home available to him in both States, he shall be
      deemed to be a resident of the State with which his personal and economic relations are closer
      (centre of vital interests);</p>
                    <p>b) if the State in which he has his centre of vital interests cannot be determined, or
      if he has not a permanent home available to him in either State, he shall be deemed to be a
      resident of the State in which he has an habitual abode;</p>
                    <p>c) if he has an habitual abode in both States or in neither of them, he shall be
      deemed to be a resident of the State of which he is a national;</p>
                    <p>d) if he is a national of both States or of neither of them, the competent authorities
      of the Contracting States shall settle the question by mutual agreement.</p>
                    <p>3. Where by reason of the provisions of paragraph 1 a person other than an individual
      is a resident of both Contracting States, the competent authorities of the Contracting States
      shall settle the question by mutual agreement and determine the mode of application of the
      Agreement to such person.</p>
                </content>
            </article>
            <article eId="art_5">
                <num>Article 5</num>
                <heading>Permanent establishment</heading>
                <content>
                    <p>1. For the purposes of this Agreement, the term "permanent establishment" means a fixed
      place of business through which the business of an enterprise is wholly or partly carried
      on.</p>
                    <p>2. The term "permanent establishment" includes especially:</p>
                    <p>a) a place of management;</p>
                    <p>b) a branch;</p>
                    <p>c) an office;</p>
                    <p>d) a factory;</p>
                    <p>e) a workshop; and</p>
                    <p>f) a mine, an oil or gas well, a quarry or any other place of extraction of natural
      resources.</p>
                    <p>3. The term "permanent establishment" likewise encompasses:</p>
                    <p>a) a building site, or a construction, assembly or installation project or supervisory
      activities in connection therewith, but only where such site, project or activities continue
      for a period of more than twelve months;</p>
                    <p>b) the furnishing of services, including consultancy or managerial services, by an
      enterprise of a Contracting State through employees or other personnel engaged by the
      enterprise for such purpose, but only where activities of that nature continue in the
      territory of the other Contracting State for a period or periods exceeding in the aggregate
      twelve months within any eighteen-month period.</p>
                    <p>4. Notwithstanding the preceding provisions of this Article, the term "permanent
      establishment" shall be deemed not to include:</p>
                    <p>a) the use of facilities solely for the purpose of storage, display or delivery of
      goods or merchandise belonging to the enterprise;</p>
                    <p>b) the maintenance of a stock of goods or merchandise belonging to the enterprise
      solely for the purpose of storage, display or delivery;</p>
                    <p>c) the maintenance of a stock of goods or merchandise belonging to the enterprise
      solely for the purpose of processing by another enterprise;</p>
                    <p>d) the maintenance of a fixed place of business solely for the purpose of purchasing
      goods or merchandise or of collecting information, for the enterprise;</p>
                    <p>e) the maintenance of a fixed place of business solely for the purpose of carrying on,
      for the enterprise, any other activity of a preparatory or auxiliary character;</p>
                    <p>f) the maintenance of a fixed place of business solely for any combination of
      activities mentioned in sub-paragraphs a) to e), provided that the overall activity of the
      fixed place of business resulting from this combination is of a preparatory or auxiliary
      character.</p>
                    <p>5. Notwithstanding the provisions of paragraphs 1 and 2, where a person – other than
      an agent of an independent status to whom paragraph 6 applies – is acting on behalf of an
      enterprise and has, and habitually exercises, in a Contracting State an authority to conclude
      contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent
      establishment in that State in respect of any activities which that person undertakes for the
      enterprise, unless the activities of such person are limited to those mentioned in paragraph 4
      which, if exercised through a fixed place of business, would not make this fixed place of
      business a permanent establishment under the provisions of that paragraph.</p>
                    <p>6. An enterprise shall not be deemed to have a permanent establishment in a
      Contracting State merely because it carries on business in that State through a broker,
      general commission agent or any other agent of an independent status, provided that such
      persons are acting in the ordinary course of their business.</p>
                    <p>7. The fact that a company which is a resident of a Contracting State controls or is
      controlled by a company which is a resident of the other Contracting State, or which carries
      on business in that other State (whether through a permanent establishment or otherwise),
      shall not of itself constitute either company a permanent establishment of the
      other.</p>
                </content>
            </article>
            <article eId="art_6">
                <num>Article 6</num>
                <heading>Income from immovable property</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State from immovable property (including
      income from agriculture or forestry) situated in the other Contracting State may be taxed in
      that other State.</p>
                    <p>2. a) The term "immovable property" shall, subject to the provisions of sub-paragraphs
      b) and c), have the meaning which it has under the law of the Contracting State in which the
      property in question is situated.</p>
                    <p>b) The term "immovable property" shall in any case include buildings, property
      accessory to immovable property, livestock and equipment used in agriculture and forestry,
      rights to which the provisions of general law respecting landed property apply, usufruct of
      immovable property and rights to variable or fixed payments as consideration for the working
      of, or the right to work, mineral deposits, sources and other natural resources.</p>
                    <p>c) Ships and aircraft shall not be regarded as immovable property.</p>
                    <p>3. The provisions of paragraph 1 shall apply to income derived from the direct use,
      letting, or use in any other form of immovable property.</p>
                    <p>4. Where the ownership of shares or other corporate rights in a company entitles the
      owner of such shares or corporate rights to the enjoyment of immovable property held by the
      company, the income from the direct use, letting, or use in any other form of such right to
      enjoyment may be taxed in the Contracting State in which the immovable property is
      situated.</p>
                    <p>5. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable
      property of an enterprise and to income from immovable property used for the performance of
      independent personal services.</p>
                </content>
            </article>
            <article eId="art_7">
                <num>Article 7</num>
                <heading>Business profits</heading>
                <content>
                    <p>1.The profits of an enterprise of a Contracting State shall be taxable only in that State
      unless the enterprise carries on business in the other Contracting State through a permanent
      establishment situated therein. If the enterprise carries on business as aforesaid, the
      profits of the enterprise may be taxed in the other State but only so much of them as is
      attributable to that permanent establishment.</p>
                    <p>2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting
      State carries on business in the other Contracting State through a permanent establishment
      situated therein, there shall in each Contracting State be attributed to that permanent
      establishment the profits which it might be expected to make if it were a distinct and
      separate enterprise engaged in the same or similar activities under the same or similar
      conditions and dealing wholly independently with the enterprise of which it is a permanent
      establishment.</p>
                    <p>3. In determining the profits of a permanent establishment, there shall be allowed as
      deductions expenses which are incurred for the purposes of the permanent establishment,
      including executive and general administrative expenses so incurred, whether in the State in
      which the permanent establishment is situated or elsewhere.</p>
                    <p>4. 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>5. Where profits include items of income which are dealt with separately in other
      Articles of this Agreement, then the provisions of those Articles shall not be affected by the
      provisions of this Article.</p>
                </content>
            </article>
            <article eId="art_8">
                <num>Article 8</num>
                <heading>Shipping and air transport</heading>
                <content>
                    <p>1.Profits of an enterprise of a Contracting State from the operation of ships or aircraft
      in international traffic shall be taxable only in that State.</p>
                    <p>2. The provisions of paragraph 1 shall also apply to profits from the participation in
      a pool, a joint business, or an international operating agency.</p>
                </content>
            </article>
            <article eId="art_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 Agreement and the competent authorities of the Contracting States
      shall if necessary consult each other.</p>
                    <p>3. A Contracting State shall not change the profits of an enterprise in the
      circumstances referred to in paragraph 1 after the expiry of the time limits provided in its
      national laws and, in any case, after six years from the end of the year in which the profits
      which would be subject to such change would have accrued to an enterprise of that
      State.</p>
                    <p>4. The provisions of paragraphs 2 and 3 shall not apply in the case of fraud, willful
      default or neglect.</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. Notwithstanding the provisions of paragraph 1, 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, dividends paid by a company which is a resident of Finland to a resident of the Czech
      Republic shall be taxable only in the Czech Republic if the recipient is the beneficial owner
      of the dividends.</p>
                    <p>3. The competent authorities of the Contracting States shall by mutual agreement
      settle the mode of application of the provisions of paragraphs 1 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. Notwithstanding the provisions of paragraph 1, the amount of dividends paid by a
      company which is a resident of the Czech Republic to the Finnish Fund for Industrial
      Co-operation Ltd (Finnfund) which shall be charged to Czech tax shall be determined by
      reducing the gross amount of the dividends by an amount equal to the amount of those dividends
      which are re-invested in the Czech Republic within the calendar year in which those dividends
      were paid.</p>
                    <p>5. 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>6. 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>7. 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 shall be taxable only in that other State if such resident is the beneficial
      owner of the interest.</p>
                    <p>2. The term "interest" as used in this Article means income from debt-claims of every
      kind, whether or not secured by mortgage and whether or not carrying a right to participate in
      the debtor's profits, and in particular, income from government securities and income from
      bonds or debentures, including premiums and prizes attaching to such securities, bonds or
      debentures. Penalty charges for late payment shall not be regarded as interest for the purpose
      of this Article.</p>
                    <p>3. The provisions of paragraph 1 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>4. 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 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>5. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the interest, having regard
      to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon
      by the payer and the beneficial owner in the absence of such relationship, the provisions of
      this Article shall apply only to the last-mentioned amount. In such case, the excess part of
      the payments shall remain taxable according to the laws of each Contracting State, due regard
      being had to the other provisions of this Agreement.</p>
                </content>
            </article>
            <article eId="art_12">
                <num>Article 12</num>
                <heading>Royalties</heading>
                <content>
                    <p>1. Royalties arising in a Contracting State and paid to a resident of the other
      Contracting State may be taxed in that other State.</p>
                    <p>2. However, such royalties, except in the case of payments of the kind referred to in
      sub-paragraph a) of paragraph 3, 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) 1 per cent of the gross amount of the royalties, in the case of payments of the
      kind referred to in sub-paragraph b) of paragraph 3;</p>
                    <p>b) 5 per cent of the gross amount of the royalties, in the case of payments of the
      kind referred to in sub-paragraph c) of paragraph 3;</p>
                    <p>c) 10 per cent of the gross amount of the royalties, in the case of payments of the
      kind referred to in sub-paragraphs d) and e) of paragraph 3.</p>
                    <p>The competent authorities of the Contracting States shall 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</p>
                    <p>a) for the use of, or the right to use, any copyright of literary, artistic or
      scientific work including cinematograph films, and films or tapes for television or radio
      broadcasting;</p>
                    <p>b) for finance lease of equipment;</p>
                    <p>c) for operating lease of equipment, or for the use of, or the right to use, any
      computer software;</p>
                    <p>d) for the use of, or the right to use, any patent, trade mark, design or model, plan,
      secret formula or process;</p>
                    <p>e) for information concerning industrial, commercial or scientific
      experience.</p>
                    <p>4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the
      royalties, being a resident of a Contracting State, carries on business in the other
      Contracting State in which the royalties arise, through a permanent establishment situated
      therein, or performs in that other State independent personal services from a fixed base
      situated therein, and the right or property in respect of which the royalties are paid is
      effectively connected with such permanent establishment or fixed base. In such case the
      provisions of Article 7 or Article 14, as the case may be, shall apply.</p>
                    <p>5. Royalties shall be deemed to arise in a Contracting State when the payer is a
      resident of that State. Where, however, the person paying the royalties, whether he is a
      resident of a Contracting State or not, has in a Contracting State a permanent establishment
      or a fixed base in connection with which the liability to pay the royalties was incurred, and
      such royalties are borne by such permanent establishment or fixed base, then such royalties
      shall be deemed to arise in the State in which the permanent establishment or fixed base is
      situated.</p>
                    <p>6. Where, by reason of a special relationship between the payer and the beneficial
      owner or between both of them and some other person, the amount of the royalties, having
      regard to the use, right or information for which they are paid, exceeds the amount which
      would have been agreed upon by the payer and the beneficial owner in the absence of such
      relationship, the provisions of this Article shall apply only to the last-mentioned amount. In
      such case, the excess part of the payments shall remain taxable according to the laws of each
      Contracting State, due regard being had to the other provisions of this Agreement.</p>
                </content>
            </article>
            <article eId="art_13">
                <num>Article 13</num>
                <heading>Capital gains</heading>
                <content>
                    <p>1. Gains derived by a resident of a Contracting State from the alienation of immovable
      property referred to in paragraph 2 of Article 6 and situated in the other Contracting State
      may be taxed in that other State.</p>
                    <p>2. Gains derived by a resident of a Contracting State from the alienation of shares or
      other corporate rights in a company the assets of which consist mainly of immovable property
      situated in the other Contracting State may be taxed in that other State.</p>
                    <p>3. Gains from the alienation of movable property forming part of the business property
      of a permanent establishment which an enterprise of a Contracting State has in the other
      Contracting State or of movable property pertaining to a fixed base available to a resident of
      a Contracting State in the other Contracting State for the purpose of performing independent
      personal services, including such gains from the alienation of such a permanent establishment
      (alone or with the whole enterprise) or of such fixed base, may be taxed in that other
      State.</p>
                    <p>4. Gains derived by 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>5. Gains from the alienation of any property other than that referred to in the
      preceding paragraphs of this Article, shall be taxable only in the Contracting State of which
      the alienator is a resident.</p>
                </content>
            </article>
            <article eId="art_14">
                <num>Article 14</num>
                <heading>Independent personal services</heading>
                <content>
                    <p>1. Income derived by a resident of a Contracting State in respect of professional
      services or other activities of an independent character shall he taxable only in that State
      except in the following circumstances, when such income may also be taxed in the other
      Contracting State:</p>
                    <p>a) if he has a fixed base regularly available to him in the other Contracting State
      for the purpose of performing his activities; in that case, only so much of the income as is
      attributable to that fixed base may be taxed in that other State; or</p>
                    <p>b) if his stay in the other State is for a period or periods exceeding in the
      aggregate 183 days within any twelve-month period; in that case, only so much of the income as
      is derived from his activities performed in that other State may be taxed in that other
      State.</p>
                    <p>2. The term "professional services" includes especially independent scientific,
      literary, artistic, educational or teaching activities as well as the independent activities
      of physicians, lawyers, engineers, architects, dentists and accountants.</p>
                </content>
            </article>
            <article eId="art_15">
                <num>Article 15</num>
                <heading>Dependent personal services</heading>
                <content>
                    <p>1. Subject to the provisions of Articles 16, 18, 19 and 20, salaries, wages and other
      similar remuneration derived by a resident of a Contracting State in respect of an employment
      shall be taxable only in that State unless the employment is exercised in the other
      Contracting State. If the employment is so exercised, such remuneration as is derived
      therefrom may be taxed in that other State.</p>
                    <p>2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident
      of a Contracting State in respect of an employment exercised in the other Contracting State
      shall be taxable only in the first-mentioned State if:</p>
                    <p>a) the recipient is present in the other State for a period or periods not exceeding
      in the aggregate 183 days within any twelve-month period, and</p>
                    <p>b) the remuneration is paid by, or on behalf of, an employer who is not a resident of
      the other State, and</p>
                    <p>c) the remuneration is not borne by a permanent establishment or a fixed base which
      the employer has in the other State.</p>
                    <p>3. Notwithstanding the preceding provisions of this Article, remuneration derived in
      respect of an employment exercised aboard a ship or aircraft operated in international traffic
      by a resident of a Contracting State, may be taxed in that State.</p>
                </content>
            </article>
            <article eId="art_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 1 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
      political subdivision or a local authority or a statutory body 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 and annuities</heading>
                <content>
                    <p>1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar
      remuneration paid to a resident of a Contracting State in consideration of past employment
      shall be taxable only in that State.</p>
                    <p>2. Notwithstanding the provisions of paragraph 1, and subject to the provisions of
      paragraph 2 of Article 19, pensions 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, or any annuity
      arising in that State, may be taxed in that State.</p>
                    <p>3. The term "annuity" as used in this Article means a stated sum payable periodically
      at stated times during life, or during a specified or ascertainable period of time, under an
      obligation to make the payments in return for adequate and full consideration in money or
      money's worth (other than services rendered).</p>
                </content>
            </article>
            <article eId="art_19">
                <num>Article 19</num>
                <heading>Government service</heading>
                <content>
                    <p>1. a) Remuneration, other than a pension, paid by a Contracting State, or a political
      subdivision, a local authority or a statutory body thereof, to an individual in respect of
      services rendered to that State, subdivision, 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
      political subdivision, a local authority or a statutory body thereof, to an individual in
      respect of services rendered to that State, subdivision, 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 political subdivision, a local authority or a statutory body thereof.</p>
                </content>
            </article>
            <article eId="art_20">
                <num>Article 20</num>
                <heading>Students</heading>
                <content>
                    <p>1. Payments which a student, or an apprentice or business, technical, agricultural or
      forestry trainee, who is or was immediately before visiting a Contracting State a resident of
      the other Contracting State and who is present in the first-mentioned State solely for the
      purpose of his education or training receives for the purpose of his maintenance, education or
      training shall not be taxed in that State, provided that such payments arise from sources
      outside that State.</p>
                    <p>2. A student at a university or other institution for higher education in a
      Contracting State, or an apprentice or business, technical, agricultural or forestry trainee,
      who is or was immediately before visiting the other Contracting State a resident of the
      first-mentioned State and who is present in the other Contracting State for a continuous
      period not exceeding 183 days, shall not be taxed in that other State in respect of
      remuneration for services rendered in that State, provided that the services are in connection
      with his studies or training and the remuneration constitutes earnings necessary for his
      maintenance.</p>
                </content>
            </article>
            <article eId="art_21">
                <num>Article 21</num>
                <heading>Other income</heading>
                <content>
                    <p>1. Items of income of a resident of a Contracting State, wherever arising, not dealt with
      in the foregoing Articles of this Agreement shall be taxable only in that State.</p>
                    <p>2. The provisions of paragraph 1 shall not apply to income, other than income from
      immovable property as defined in paragraph 2 of Article 6, if the recipient of such income,
      being a resident of a Contracting State, carries on business in the other Contracting State
      through a permanent establishment situated therein, or performs in that other State
      independent personal services from a fixed base situated therein, and the right or property in
      respect of which the income is paid is effectively connected with such permanent establishment
      or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be,
      shall apply.</p>
                </content>
            </article>
            <article eId="art_22">
                <num>Article 22</num>
                <heading>Elimination of double taxation</heading>
                <content>
                    <p>1. In Finland double taxation shall be eliminated as follows:</p>
                    <p>a) Where a resident of Finland derives income which, in accordance with the provisions
      of this Agreement, may be taxed in the Czech Republic, Finland shall, subject to the provision
      of sub-paragraph b), allow as a deduction from the tax on the income of that person an amount
      equal to the tax on income paid in the Czech Republic. Such deduction shall not, however,
      exceed that part of the tax on the income, as computed before the deduction is given, which is
      attributable to the income which may be taxed in the Czech Republic.</p>
                    <p>b) Dividends paid by a company which is a resident of the Czech Republic 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 Agreement, an individual who is a
      resident of the Czech Republic 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 Czech tax paid on income as a deduction from Finnish
      tax in accordance with the provisions of sub-paragraph a). The provisions of this
      sub-paragraph shall apply only to nationals of Finland.</p>
                    <p>d) Where in accordance with any provision of the Agreement income derived by a
      resident of Finland is exempt from tax in Finland, Finland may nevertheless, in calculating
      the amount of tax on the remaining income of such person, take into account the exempted
      income.</p>
                    <p>2. In the Czech Republic double taxation shall be eliminated as follows:</p>
                    <p>The Czech Republic when imposing taxes on its residents may include in the tax base
      upon which such taxes are imposed the items of income which according to the provisions of
      this Agreement may also be taxed in Finland, but shall allow as a deduction from the amount of
      tax computed on such a base an amount equal to the tax paid in Finland. Such deduction shall
      not, however, exceed that part of the Czech tax, as computed before the deduction is given,
      which is appropriate to the income which, in accordance with the provisions of this Agreement,
      may be taxed in Finland.</p>
                </content>
            </article>
            <article eId="art_23">
                <num>Article 23</num>
                <heading>Non-discrimination</heading>
                <content>
                    <p>1. Nationals of a Contracting State shall not be subjected in the other Contracting State
      to any taxation or any requirement connected therewith, which is other or more burdensome than
      the taxation and connected requirements to which nationals of that other State in the same
      circumstances are or may be subjected. This provision shall, notwithstanding the provisions of
      Article 1, also apply to persons who are not residents of one or both of the Contracting
      States.</p>
                    <p>2. The taxation on a permanent establishment which an enterprise of a Contracting
      State has in the other Contracting State shall not be less favourably levied in that other
      State than the taxation levied on enterprises of that other State carrying on the same
      activities. This provision shall not be construed as obliging a Contracting State to grant to
      residents of the other Contracting State any personal allowances, reliefs and reductions for
      taxation purposes on account of civil status or family responsibilities which it grants to its
      own residents.</p>
                    <p>3. Except where the provisions of paragraph 1 of Article 9, paragraph 5 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.</p>
                    <p>4. Enterprises of a Contracting State, the capital of which is wholly or partly owned
      or controlled, directly or indirectly, by one or more residents of the other Contracting
      State, shall not be subjected in the first-mentioned State to any taxation or any requirement
      connected therewith which is other or more burdensome than the taxation and connected
      requirements to which other similar enterprises of the first-mentioned State are or may be
      subjected.</p>
                    <p>5. The provisions of this Article shall, notwithstanding the provisions of Article 2,
      apply to taxes of every kind and description.</p>
                </content>
            </article>
            <article eId="art_24">
                <num>Article 24</num>
                <heading>Mutual agreement procedure</heading>
                <content>
                    <p>
                        <embeddedStructure class="mli-replaced">
                            <p>
                                <authorialNote>
                                    <p>1. [The first sentence of paragraph 1 of Article 24 of this Agreement 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
        Agreement, he may, irrespective of the remedies provided by the domestic law of those
        States, present his case to the competent authority of the Contracting State of which he is
        a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting
        State of which he is a national.] The case must be presented within three years from the first notification of the
      action resulting in taxation not in accordance with the provisions of the
      Agreement.</p>
                        </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 24 of this Agreement:
                                        <authorialNote marker="2" placement="bottom">
                                            <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, the first
            sentence of paragraph 1 of Article 16 of the MLI has effect with respect to the
            application of this Agreement by the Republic of Finland:</p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            nonresidents, where the event giving rise to such taxes occurs on or after 1 January
            2021; and</p>
                                            <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2022;</p>
                                            <p>and,</p>
                                            <p>In accordance with paragraph 1 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
            Agreement by the Czech Republic:</p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            nonresidents, where the event giving rise to such taxes occurs on or after 1 January
            2021; and</p>
                                            <p>b) with respect to all other taxes levied by the Czech Republic, for taxes
            levied with respect to taxable periods beginning on or after 1 March 2021.</p>
                                        </authorialNote>
                                    </p>
                                </authorialNote>
                            </p>
                            <article>
                                <num>ARTICLE 16 OF THE MLI – MUTUAL AGREEMENT PROCEDURE</num>
                                <content>
                                    <p>
                                        Where a person considers that the actions of one or both of the
            [
                                        <i>Contracting States</i>
                                        ] result or will result for that person in
          taxation not in accordance with the provisions of [
                                        <i>this Agreement</i>
                                        ],
          that person may, irrespective of the remedies provided by the domestic law of those
            [C
                                        <i>ontracting States</i>
                                        ], present the case to the competent authority
          of either [
                                        <i>Contracting State</i>
                                        ].
                                    </p>
                                </content>
                            </article>
                        </embeddedStructure>
                    </p>
                    <p>2. The competent authority shall endeavour, if the objection appears to it to be
      justified and if it is not itself able to arrive at a satisfactory solution, to resolve the
      case by mutual agreement with the competent authority of the other Contracting State, with a
      view to the avoidance of taxation which is not in accordance with the Agreement. In the event
      the competent authorities reach an agreement, taxes shall be imposed, and refund or credit of
      taxes shall be allowed by the Contracting States in accordance with such agreement. Any
      agreement reached shall be implemented notwithstanding any time limits in the domestic law of
      the Contracting States.</p>
                    <p>3. The competent authorities of the Contracting States shall endeavour to resolve by
      mutual agreement any difficulties or doubts arising as to the interpretation or application of
      the Agreement. They may also consult together for the elimination of double taxation in cases
      not provided for in the Agreement.</p>
                    <p>4. The competent authorities of the Contracting States may communicate with each other
      directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.
      When it seems advisable in order to reach agreement to have an oral exchange of opinions, such
      exchange may take place through a Commission consisting of representatives of the competent
      authorities of the Contracting States.</p>
                </content>
            </article>
            <article eId="art_25">
                <num>Article 25</num>
                <heading>Exchange of information</heading>
                <content>
                    <p>1. The competent authorities of the Contracting States shall exchange such information as
      is relevant for carrying out the provisions of this Agreement or of the domestic laws of the
      Contracting States concerning taxes covered by the Agreement insofar as the taxation
      thereunder is not contrary to the Agreement. The exchange of information is not restricted by
      Article 1. Any information received by a Contracting State shall be treated as secret in the
      same manner as information obtained under the domestic laws of that State and shall be
      disclosed only to persons or authorities (including courts and administrative bodies) 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 Agreement. Such persons or
      authorities shall use the information only for such purposes. They may disclose the
      information in public court proceedings or in judicial decisions.</p>
                    <p>2. In no case shall the provisions of paragraph l 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_26">
                <num>Article 26</num>
                <heading>Members of diplomatic missions and consular posts</heading>
                <content>
                    <p>Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic
      missions or consular posts under the general rules of international law or under the
      provisions of special agreements.</p>
                    <p>
                        <embeddedStructure class="mli-replacement">
                            <p>
                                <authorialNote>
                                    <p>
                                        The following paragraph 1 of Article 7 of the MLI applies and supersedes the
        provisions of this Agreement:
                                        <authorialNote marker="3" placement="bottom">
                                            <p>In accordance with paragraphs 1 and 3 of Article 35 of the MLI, paragraph 1 of
            Article 7 of the MLI has effect with respect to the application of this Agreement by the
            Republic of Finland:</p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            nonresidents, where the event giving rise to such taxes occurs on or after 1 January
            2021; and</p>
                                            <p>b) with respect to all other taxes levied by the Republic of Finland, for taxes
            levied with respect to taxable periods beginning on or after 1 January 2022;</p>
                                            <p>and,</p>
                                            <p>In accordance with paragraph 1 of Article 35 of the MLI, paragraph 1 of Article
            7 of the MLI has effect with respect to the application of the Agreement by the Czech
            Republic:</p>
                                            <p>a) with respect to taxes withheld at source on amounts paid or credited to
            nonresidents, where the event giving rise to such taxes occurs on or after 1 January
            2021; and</p>
                                            <p>b) with respect to all other taxes levied by the Czech Republic, for taxes
            levied with respect to taxable periods beginning on or after 1 March 2021.</p>
                                        </authorialNote>
                                    </p>
                                </authorialNote>
                            </p>
                            <article>
                                <num>ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal purposes test provision)</num>
                                <content>
                                    <p>
                                        Notwithstanding any provisions of [
                                        <i>the Agreement</i>
                                        ], a
          benefit under [
                                        <i>the Agreement</i>
                                        ] shall not be granted in respect of an
          item of income [ ] if it is reasonable to conclude, having regard to all relevant facts
          and circumstances, that obtaining that benefit was one of the principal purposes of any
          arrangement or transaction that resulted directly or indirectly in that benefit, unless it
          is established that granting that benefit in these circumstances would be in accordance
          with the object and purpose of the relevant provisions of [
                                        <i>the
            Agreement</i>
                                        ].
                                    </p>
                                </content>
                            </article>
                        </embeddedStructure>
                    </p>
                </content>
            </article>
            <article eId="art_27">
                <num>Article 27</num>
                <heading>Entry into force</heading>
                <content>
                    <p>1. The Governments of the Contracting States shall notify each other that the
      constitutional requirements for the entry into force of this Agreement have been complied
      with.</p>
                    <p>2. The Agreement shall enter into force fifteen days after the date of the later of
      the notifications referred to in paragraph 1 and its provisions shall have effect in both
      Contracting States:</p>
                    <p>a) in respect of taxes withheld at source, on income derived on or after 1 January in
      the calendar year next following the year in which the Agreement enters into force;</p>
                    <p>b) in respect of other taxes on income, for taxes chargeable for any tax year
      beginning on or after 1 January in the calendar year next following the year in which the
      Agreement enters into force.</p>
                    <p>3. The Convention between the Government of the Republic of Finland and the Government
      of the Czechoslovak Socialist Republic for the Avoidance of Double Taxation and the Prevention
      of Fiscal Evasion with Respect to Taxes on Income and on Capital, signed at Helsinki on 31
      January 1975, (hereinafter referred to as "the 1975 Convention"), shall cease to have effect
      with respect to taxes to which this Agreement applies in accordance with the provisions of
      paragraph 2. The 1975 Convention shall terminate on the last date on which it has effect in
      accordance with the foregoing provision of this paragraph.</p>
                </content>
            </article>
            <article eId="art_28">
                <num>Article 28</num>
                <heading>Termination</heading>
                <content>
                    <p>This Agreement shall remain in force until terminated by a Contracting State. Either
      Contracting State may terminate the Agreement, through diplomatic channels, by giving notice
      of termination at least six months before the end of any calendar year following after the
      period of five years from the date on which the Agreement enters into force. In such event,
      the Agreement shall cease to have effect in both Contracting States:</p>
                    <p>a) in respect of taxes withheld at source, on income derived on or after 1 January in
      the calendar year next following the year in which the notice is given;</p>
                    <p>b) in respect of other taxes on income, for taxes chargeable for any tax year
      beginning on or after 1 January in the calendar year next following the year in which the
      notice is given.</p>
                    <p>In witness whereof the undersigned, duly authorised thereto, have signed this
      Agreement.</p>
                    <p>Done in duplicate at Prague this 2nd day of December 1994, in the English
      language.</p>
                </content>
            </article>
        </mainBody>
    </doc>
</akomaNtoso>
