55/2005 and 78/2005 Convention on automatic exchange of information

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1 INCOME TAX TREATIES AND AGREEMENTS ON THE TAXATION OF INCOME FROM SAV- INGS (IN FORCE, SIGNED, INITIALLED OR IN NEGOTIATING PROCESS, SITUATION ON 25th April 2018) Country Year of conclusion Number in the Additional information Finnish Treaty Series Anguilla 57/2005 Convention on automatic exchange of information about savings income in the form of interest payments. (see AGREEMENTS ON MUTUAL ADMINISTRATIVE AS- SISTANCE IN TAX MATTERS) Argentina /1996 Armenia /2007 The agreement is applied as of 1st January Aruba /2011 Agreement for Promotion of Economic Relations and a TIEA (see AGREEMENTS ON MUTUAL ADMINISTRATIVE AS- SISTANCE IN TAX MATTERS) have entered into force on 1 st of June Government Proposal to Parliament 200/ /2005 and 78/2005 Convention on automatic exchange of information about savings income in the form of interest payments. Australia / /2013 The new agreement is applied as of 1st January The Contracting Parties have agreed on the correction of a technical error in the Protocol in October Austria Amending Protocol / /2011 Amending protocol entre into force on 1 st December Government Proposal to Parliament 13/2011. Azerbaijan /2006 The agreement is applied as of 1st January Barbados / /2013 Amending Protocol is applied as of 23 March Belgium 1976 Amended in / / /2014 Amending protocol on Exchange of Information entered into force 18 th July Bermuda /2009 Three Income Tax Agreements: For the Avoidance of Double Taxation on Individuals, for the Avoidance of Double Taxation with Respect to Enterprises Operating Ships or Aircraft in International Traffic and on the Access to Mutual Agreement Procedures in Connection with the Adjustment of Profits of Associated Enterprises, as well as TIEA

2 entered into force on 31st December Bosnia-Herzegovina 75/2005 Agreement between Finland and Socialistic Republic of Yugoslavia is applied (Number in the Finnish Treaty Series: 60/1987). Brazil /1997 Tax sparing ends and internal rates are applied as of 1st January 2008 to dividend, interest and royalty. British Virgin Islands / /2005 Agreements for the Avoidance of Double Taxation on Individuals, for the Avoidance of Double Taxation with Respect to Enterprises Operating Ships or Aircraft in International Traffic and on the Access to Mutual Agreement Procedures in Connection with the Adjustment of Profits of Associated Enterprises, as well as TIEA (see AGREE- MENTS ON MUTUAL ADMINISTRA- TIVE ASSISTANCE IN TAX MATTERS. Agreement on Taxation of Savings Income. Bulgaria /1986 Byelorussia /2008 The agreement is applied as of 1st January Canada /2007 Cayman Islands / /2005 Agreements for the Avoidance of Double Taxation on Individuals, for the Avoidance of Double Taxation with Respect to Enterprises Operating Ships or Aircraft in International Traffic and on the Access to Mutual Agreement Procedures in Connection with the Adjustment of Profits of Associated Enterprises, as well as TIEA. Agreement on Taxation of Savings Income. Chile No treaty Negotiations have taken place, open questions are discussed through correspondence. China / /2006 Agreement on the reciprocal exemption from certain taxes concerning international air transport business. Croatia /1995 Agreement between Finland and the Socialistic Republic of Yugoslavia is applied (Number in the Finnish Treaty Series: 60/1987). Cyprus /2013 The agreement is applied as of 1st January Czech /1995 5/1996 Denmark (and Faeroe Islands) 1996 Amended in 1997 Amended in / / / Amending protocol is applied mainly as of 1st January Egypt /1966 Negotiations on a new agreement have taken

3 Amended in /1976 place in October Estonia / /2016 The MFN-clause in Article 12 (Royalty) paragraph 7 of the Agreement has been fulfilled. From the beginning of 2016 royalty is no longer subject to tax in the Contracting State from which it is derived. The definition of royalty has been changed as follows: 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. (Thus, Article 12 is no longer applied to leasing). France /1972 New draft agreement has been initialled on 28 April Germany / /2017 The new Agreement is applied as of 1 st January Georgia /2008 The agreement is applied as of 1st January Greece /1981 Guernsey / /2005 Agreements for the Avoidance of Double Taxation on Individuals, for the Avoidance of Double Taxation with Respect to Enterprises Operating Ships or Aircraft in International Traffic and on the Access to Mutual Agreement Procedures in Connection with the Adjustment of Profits of Associated Enterprises, as well as TIEA. Agreement on Taxation of Savings Income. Hong Kong /2008 Agreement for the Avoidance of Double Taxation with Respect to Taxes on Income from Aircraft Operation. Negotiations on a new agreement have been held, open questions are discussed through correspondence. Hungary /1981 New draft agreement with some open points has been initialled on 27th November Iceland 1996 Amended in 1997 Amended in / / / Amending protocol is applied mainly as of 1st January 2009.

4 India /2010 Indonesia /1989 Ireland /1993 Isle of Man / / Agreements for the Avoidance of Double Taxation on Individuals, for the Avoidance of Double Taxation with Respect to Enterprises Operating Ships or Aircraft in International Traffic and on the Access to Mutual Agreement Procedures in Connection with the Adjustment of Profits of Associated Enterprises, as well as. Agreement on Taxation of Savings Income. Israel /1998 Italy /1983 Draft amending protocol has been initialled on 7th June Japan 1972 Amended in 1991 Jersey / / / / /2005 Agreements for the Avoidance of Double Taxation on Individuals, for the Avoidance of Double Taxation with Respect to Enterprises Operating Ships or Aircraft in International Traffic and on the Access to Mutual Agreement Procedures in Connection with the Adjustment of Profits of Associated Enterprises, as well as TIEA (see AGREE- MENTS ON MUTUAL ADMINISTRA- TIVE ASSISTANCE IN TAX MAT- TERS). Agreement on Taxation of Savings Income. Kazakhstan /2010 Kuwait No treaty Negotiations have taken place in April Kyrgyzstan / Latvia /1993 Lebanon No treaty Draft agreement with some open points has been initialled on 13th January Lithuania /1993 Luxembourg 1982 Amended / / /2010 Protocol amending exchange of information rules. Macedonia /2002 Malaysia /1986 Negotiations on a new agreement have taken place in November Malta /2001 Mexico /1998 Moldova /2008 Montenegro 45/2007 Agreement between Finland and the Social-

5 istic Republic of Yugoslavia is applied (Number in the Finnish Treaty Series: 60/1987). Montserrat 63/2005 Agreement on Taxation of Savings Income. (see AGREEMENTS ON MUTUAL AD- MINISTRATIVE ASSISTANCE IN TAX MATTERS). Morocco /2013 Netherlands /1997 See also Netherlands Antilles and Aruba Netherlands Antilles /2011 Agreement for Promotion of Economic Relations and a TIEA (see AGREEMENTS ON MUTUAL ADMINISTRATIVE AS- SISTANCE IN TAX MATTERS). 53/2005 and 77/2005 Convention on automatic exchange of information about savings income in the form 6/2017 of interest payments. Finland och Netherlands have agreed that the Convention is no longer from 1 January 2017 applied between Finland and Netherlands in respect of the islands of Bonaire, Curaçao, Saba and Sint Eustatius. But it is still applied to the Dutch part of island of St. Maarten. New Zealand 1982 Amended in / / Draft amending protocol has been initialled on 20th September Nigeria No treaty Draft agreement was initialled on 5th July Norway 1996 Amended in 1997 Amended in 2008 Oman 26/ / /2008 Pakistan /1996 Philippines 1978 Amended in /1981 Not yet published Negotiations on Income Tax Treaty have taken place in March Amendment has been accepted in Finland but is not yet in force. Government Proposal to Parliament 244/1994. Poland /2010 Portugal /1971 A new Agreement, Government s Proposal to the Parliament 246/2016/ , accepted by the Parliament. Date of entry into force is not yet known. Qatar No treaty Negotiations have taken place in December 2002 and in January Rumania /2000 Russia 1996 and /2002 Negotiations on amending protocol have been held. Saudi-Arabia No treaty Negotiations have taken place in 2008.

6 Serbia 9/2016 Agreement between Finland and the Socialistic Republic of Yugoslavia is applied (Number in the Finnish Treaty Series: 60/1987). Singapore / /4010 Slovakia /2000 Slovenia / South Africa /1995 4/1996 South Korea /1981 Draft amending protocol has been agreed on through correspondence. Spain 1967 Amended in 1970 Amended in 1973 Amended in Sri Lanka Sweden 1996 Amended in 1997 Amended in 2008 Switzerland / / / / A new Agreement, Government s Proposal to the Parliament 5/2016/ , accepted by the Parliament. Date of entry into force is not yet known. 20/ /2018 The new Agreement is applied from 1 st January / / / / / / /2013 Amending protocol entered into force on 19 th December 2010 and is applied as of 1 st January Also an EU-Agreement on taxation of income from savings. Tajikistan /2013 Agreement is applied as of 1st January Tanzania /1978 Thailand /1986 Tunisia No treaty Negotiations have taken place, open questions are discussed through correspondence. Turkey /2012 Turkmenistan /2017 Agreement is applied as of 1 st January Turks and Caicos Islands 65/2005 Agreement on Taxation of Savings Income. (see AGREEMENTS ON MUTUAL AD- MINISTRATIVE ASSISTANCE IN TAX MATTERS) Ukraine /1995 6/1996 United Arab Emir /1997 Negotiations on an amending protocol have

7 ates 2016 United Kingdom 1969 Amended in 1973 Amended in 1979 Amended in 1985 Amended in 1991 Amended in 1996 United States of America 1989 Amending protocol of / / /1981 8/1987 2/ /1997 2/1991 3/ taken place in September 2012 and also after that through correspondence. Agreement on exchange of information has been concluded 27th March /2015 FATCA, Agreement between the Government of the Republic of Finland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA Uruguay /2013 The Agreement is in force as of 6 th February Uzbekistan (applied as of 1 st January 2014). 10/ /2016 Amending protocol (Exchange of information, assistance in the collection) Vietnam /2002 Yugoslavia /1987 The Socialistic Republic of Yugoslavia has ceased to exist. Zambia /1985 Draft amending protocol has been agreed on through correspondence. INHERITANCE AND GIFT TAX TREATIES (IN FORCE, SIGNED, INITIALLED OR IN NEGOTIATING PROCESS, SITUATION ON 25th April 2018) Country Year of conclusion Number in the Additional information Finnish Treaty Series Denmark / /1992 Nordic Multilateral Convention (Faroe Island and Greenland are not covered by this agreement) France /1959 Germany No treaty Negotiations on an agreement were held in September Iceland /1992 Nordic Multilateral Convention 103/1993 Italy No treaty Draft agreement has been initialled on 4 June Netherlands /1955 Norway / /1993 Nordic Multilateral Convention

8 8 Sweden / /1993 Switzerland /1957 United States of /1952 America Nordic Multilateral Convention. The Convention ceased to apply to Sweden on 24 August Sweden no longer taxes inheritance and gifts. AGREEMENTS ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS IN FORCE AND TAX INFORMATION EXCHANGE AGREEMENTS (TIEA), SIGNED, INITIALLED OR TO BE NEGOTIATED (SITUATION ON 25th April 2018) Country Year of conclusion Number in the Additional information Finnish Treaty Series Andorra /2011 TIEA entered into force on 12 th February Government Proposal to the Parliament 10/2010. Also an EU-Agreement on taxation of income from savings. Anguilla 2009 TIEA entered into force on 10 th April Government Proposal to Parliament 278/2009. Convention on automatic exchange of information about savings income in the form of interest payments, see Income Tax Treaties Antigua and Barbuda /2011 TIEA entered into force on 24 th March Government Proposal to Parliament 82/2010. Aruba /2011 TIEA and Agreement for Promotion of Economic Relations (see Income Tax Treaties) have entered into force on 1 st of June Government Proposal to Parliament 200/2009. Convention on automatic exchange of information about savings income in the form of interest payments, see Income Tax Treaties Bahamas /2010 TIEA entered into force on 9 th September Amending protocol on automatic exchange was signed 19 October Bahrain 58/2012 TIEA is in force as of 11 th July Belize /2013 TIEA entered into force on 26th February Bermuda /2009 Three income tax agreements (see IN- COME TAX TREATIES) and TIEA entered into force on 31st December Botswana /2015 TIEA is in force as of 16 th May 2015.

9 British Virgin Islands /2011 TIEA and three income tax agreements (see INCOME TAX TREATIES) entered into force on 20 th May 2011 Government Proposal to Parliament 128/2009. Agreement on Taxation of Income from Savings, see Income Tax Treaties. Brunei /2015 TIEA is in force as of 1 st May Cayman Islands 2009 Three income tax agreements (see IN- COME TAX TREATIES) and TIEA entered into force 31 st March Agreement on Taxation of Income from Savings, See Income Tax Treaties. Cook Islands /2012 TIEA entered into force 2nd October Costa Rica 2011 TIEA was signed on 29th June It has already been dealt with by the Parliament but is not yet in force. Government Proposal to Parliament 21/2011. Council of Europe/OECD /1995 Amending Protocol /2011 Amending Protocol has entered into force on 1 st June Government Proposal to Parliament 209/2010. Dominica /2013 TIEA entered into force on 27th March Gibraltar /2010 TIEA entered into force 6 th May Grenada /2012 TIEA is in force as of 22 nd February Guatemala 2011 TIEA signed 15th May 2012 has been dealt with by the Parliament but is not yet in force. Government Proposal to Parliament 51/2012. Guernsey /2009 Three income tax agreements (see IN- COME TAX TREATIES) and TIEA entered into force on 11 th November 2009 and 5 th April 2009 (TIEA). Agreement on Taxation of Savings Income, see Income Tax Treaties Isle of Man /2008 Three income tax agreements (see IN- COME TAX TREATIES) and TIEA entered into force 19 th June Agreement on Taxation of Savings Income, see Income Tax Treaties Jamaica /2015 TIEA is in force as of 18 th October Jersey /2009 Three income tax agreements (see IN- COME TAX TREATIES) and TIEA entered into force 2 nd August Agreement on Taxation of Savings Income, see Income Tax Treaties. Liberia /2013 TIEA is in force as of 12 th June

10 Liechtenstein /2012 TIEA is in force as of 4 th April Macao (The Macao Special Administrative Region of the People's Republic of China) /2012 TIEA entered into force 9 th December Marshall Islands 51/2012 TIEA is in force as of 4th December Mauritius /2012 TIEA is in force as of 6 th July Monaco 2010 TIEA entered into force 20 th November Government Proposal to Parliament 105/2010. Also an EU-Agreement on taxation of income from savings. Montserrat /2011 TIEA entered into force 31 st December2011. Government Proposal to Parliament 289/2010. Netherlands Antilles /2011 TIEA and Agreement for Promotion of Economic Relations (see INCOME TAX TREATIES) have entered into force on 1 st of June Government Proposal to Parliament 199/2009. Convention on automatic exchange of information about savings income in the form of interest payments, see Income Tax Treaties Nordic countries (including Faeroe Islands, Greenland) /1991 Negotiations on a new agreement have taken place Niue 2013 Governments TIEA-proposal (nr 179/2013 rd) has been given to the Parliament on 7th November Panama /2014 TIEA entered into force on 20th December Samoa /2013 TIEA entered into force on 20th October Seychelles /2012 TIEA entered into force on 8 th November St. Kitts and Nevis /2011 TIEA entered into force on 23rd March Government Proposal to Parliament 38/2010. St. Lucia 2010 TIEA entered into force on 17 th March Government Proposal to Parliament 85/2010. St. Vincent and Grenadines Turks and Caicos Islands /2011 TIEA entered into force on 28 th April Government Proposal to Parliament 39/ /2011 TIEA entered into force on 2 nd April Government Proposal to Parliament 10

11 281/2009. Agreement on Taxation of Savings Income, see Income Tax Treaties. United Arab Emirates /2017 TIEA entered into force on 10th February 2017, applied as of , for criminal tax matters from the date of entry into force. United States of America /2015 FATCA, Agreement between the Government of the Republic of Finland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA Vanuatu /2011 TIEA entered into force on 24 th March Government Proposal to Parliament 233/ AGREEMENTS BETWEEN COMPETENT AUTHORITIES FOR IMPLEMENTATION OF DIF- FERENT AGREEMENTS (IN FORCE, SIGNED, INITIALLED OR IN NEGOTIATING PROCESS, SITUATION ON 25th April 2018) Country Year of conclusion Number in the Additional information Finnish Treaty Series Estonia / Exchange of information, simultaneous tax examinations and recovery of taxes Italy 1997 Exchange of information, simultaneous tax examinations Latvia /2003 Exchange of information, simultaneous tax examinations Lithuania /2003 Exchange of information, simultaneous tax examinations Poland / Exchange of information, simultaneous tax examinations United States of /2003 Simultaneous tax examinations America UPDATED ON 25th April 2018

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