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Finland - Germany Tax Treaty (as amended by 2019 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State, one of its "Länder", or one of their political subdivisions or local authorities, irrespective of the manner in which they are levied.

(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, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are:

  • (a) In the case of the Federal Republic of Germany:
    • (i) the income tax (Einkommensteuer);
    • (ii) the corporate income tax (Körperschaftsteuer); and
    • (iii) the trade tax (Gewerbesteuer);
  • including the supplements levied thereon
  • (hereinafter referred to as "German tax");
  • (b) In the case of the Republic of Finland:
    • (i) the state income taxes (valtiontuloverot; de statligainkomstskatterna);
    • (ii) the corporate income tax (yhteisöjentulovero; inkomstskattenförsamfund);
    • (iii) the communal tax (kunnallisvero; kommunalskatten);
    • (iv) the church tax (kirkollisvero; kyrkoskatten);
    • (v) the tax withheld at source from interest (korkotulonlähdevero; källskattenpåränteinkomst); and
    • (vi) the tax withheld at source from non-residents' income (rajoitetustiverovelvollisenlähdevero; källskattenförbegränsatskattskyldig);
  • (hereinafter referred to as "Finnish tax").

(4) The Convention shall also apply to any identical or substantially similar taxes that are imposed after the date of signature of the Convention 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 that have been made in their taxation laws.