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Finland Publishes Notification on Triggering of Royalties MFN Clause in Tax Treaty with Latvia

|Treaty Development|Finland-Latvia
Finland-Latvia

Finland has published Notification No. 15/2021 of 3 March 2021, which includes that the MFN clause contained in paragraph 7 of Article 12 (Royalties) of the 1993 tax treaty with Latvia has been triggered with effect from 1 January 2018. As a result, the following provisions apply:

  • Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other Contracting State (i.e., exempt from withholding tax); and
  • The term …

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