Dividend taxation: source and residence states share taxing rights, with limited source taxation and treaty exemption for resident recipients.

Article 11 allocates taxing rights over dividends between source and residence states, permitting residence taxation and limited source taxation; it preserves taxation of the distributing company's profits and defines dividends as income from shares and similar profit-participating corporate rights. A Finland-specific rule substitutes an exemption for dividends paid to residents of the other Contracting State where a Finnish resident individual is entitled to a domestic tax credit. The article disapplies these rules for holdings effectively connected with a permanent establishment or fixed base, invoking the provisions on business profits or independent personal services, and limits taxation of undistributed profits.

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