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Finland Publishes Synthesized Text of Tax Treaties with Barbados and Croatia as Impacted by the BEPS MLI — Orbitax Tax News & Alerts

Finland's Ministry of Justice has published the synthesized texts of the 1989 income tax treaty with Barbados and the 1986 income and capital tax treaty with Croatia (former Yugoslavia) as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 1989 Finland-Barbados tax treaty:

  • In Finland:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
    • with respect to all other taxes levied by Finland, for taxes levied with respect to taxable periods beginning on or after 1 January 2022;
  • In Barbados:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
    • with respect to all other taxes levied by Barbados, for taxes levied with respect to taxable periods beginning on or after 1 October 2021.

Notwithstanding the above, the provisions of Part VI (Arbitration) of the MLI have effect with respect to the treaty for cases presented to the competent authority of a Contracting State on or after 1 April 2021, and for cases presented prior to that date to the extent agreed by the competent authorities.

The MLI applies for the 1986 Finland-Croatia (former Yugoslavia) tax treaty:

  • In Finland:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
    • with respect to all other taxes levied by Finland, for taxes levied with respect to taxable periods beginning on or after 1 January 2022;
  • In Croatia:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
    • with respect to all other taxes levied by Croatia, for taxes levied with respect to taxable periods beginning on or after 1 December 2021.

Click the following link for the tax treaty page on the Ministry of Justice FINLEX website, which includes the synthesized texts of Finland's tax treaties.