https://www.taxtmi.com/acts?id=4651 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. en-us Sat, 19 Jan 2008 22:45:54 +0530 Fri, 06 Mar 2009 11:21:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4651 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. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4651