India's Income Tax Department has published the synthesized text of the 2010 India-Finland income tax treaty as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text was prepared on the basis of the reservations and notifications submitted to the Depositary (the Secretary-General of the Organisation for Economic Co-operation and Development) by India on 25 June 2019 and by Finland on 25 February 2019. The authentic legal texts of the Agreement and the MLI take precedence and remain the legal texts applicable.
The MLI entered into force on 1 October 2019 for India and on 1 June 2019 for Finland and has effect:
- in India:
- 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 April 2020; and
- with respect to all other taxes levied by India, for taxes levied with respect to taxable periods beginning on or after 1 April 2020; and
- 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 2020; and
- with respect to all other taxes levied by Finland, for taxes levied with respect to taxable periods beginning on or after 1 January 2021.
Click the following link for the text of the 2010 India-Finland income tax treaty as impacted by the MLI.