Document ID: chunk:federal_register_of_legislation:C2007A00146:schedule:25:p1
Version: federal_register_of_legislation:C2007A00146
Segment Type: schedule
Provision Reference: sch 25 (pt 1/27)
Character Range: 2983–5947

Schedule 25—2006 Finnish agreement

Note: See section 3.

AGREEMENT BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF FINLAND FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF FISCAL EVASION

The Government of Australia and the Government of Finland,

Desiring to conclude an Agreement for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion,

Have agreed as follows:

CHAPTER I

SCOPE OF THE AGREEMENT

ARTICLE 1

Persons Covered

 This Agreement shall apply to persons who are residents of one or both of the Contracting States.

ARTICLE 2

Taxes Covered

1. The existing taxes to which this Agreement shall apply are:

     a) in the case of Australia:

         the income tax, including the resource rent tax in respect of offshore projects relating to exploration for or exploitation of petroleum resources, imposed under the federal law of Australia.

 b) in the case of Finland:

             (i) the state income taxes;

             (ii) the corporate income tax;

             (iii) the communal tax;

             (iv) the church tax;

             (v) the tax withheld at source from interest; and

             (vi) the tax withheld at source from non‑residents' income.

2. The Agreement shall apply also to any identical or substantially similar taxes that are imposed under the federal law of Australia or the law of Finland 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 that have been made in the law of their respective States relating to the taxes to which the Agreement applies within a reasonable period of time after those changes.

3. For the purposes of Article 23, the taxes to which this Agreement shall apply are taxes of every kind and description imposed on behalf of the Contracting States, or their political subdivisions or local authorities.

4. For the purposes of Articles 25 and 26, the taxes to which this Agreement shall apply are:

        a) in the case of Australia, taxes of every kind and description imposed under the federal tax laws administered by the Commissioner of Taxation; and

        b) in the case of Finland, taxes of every kind and description.

CHAPTER II

DEFINITIONS

ARTICLE 3

General Definitions

1. For the purposes of this Agreement, unless the context otherwise requires:

        a) the term "Australia", when used in a geographical sense, excludes all external territories other than:

             (i) the Territory of Norfolk Island;

             (ii) the Territory of Christmas Island;

             (iii) the Territory of Cocos (Keeling) Islands;

             (iv) the Territory of Ashmore and Cartier Islands;

             (v) the Territory of Heard Island and McDonald Islands; and

             (vi) the Coral Sea Islands Territory,