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Finland Confirms Exemption for Royalties based on MFN Clause in Tax Treaty with Estonia

|Treaty Development|Finland-Estonia
Finland-Estonia

The Finnish tax administration issued a release on 3 October 2016 confirming that based on the MFN clause in the 1993 Estonia-Finland tax treaty, royalties are exempt from withholding tax effective from 1 January 2016. Although not mentioned in the release, the MFN clause was triggered by the 2014 protocol to the 2002 Estonia-Switzerland tax treaty, which provides for an exemption. According to the release, with the triggering of the clause, paragraphs 2 and 3 of Article 12 (Royalties) are ef…

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