Persons Covered

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....of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 15th January, 2010 (the "Agreement"), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and the Finland on 7th June, 2017 (the "MLI"). The document was prepared on the basis of the MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Finland submitted to the Depositary upon acceptance on 25th February, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of the MLI on this Agreement. The docume....

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....o the Agreement as modified by the provisions of the MLI, provided such provisions of the MLI have taken effect. References: The authentic legal text of the MLI (in English) can be found on the MLI Depository (OECD) webpage at the following link: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf The authentic legal texts of the Agreement (in English) can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx The authentic legal texts of the Agreement (in Finnish language) can be found at the following link: https://finlex.fi/fi/sopimukset/sopsteksti/2010/20100058 The MLI position of the India submitted to the Deposi....

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....aid or credited to non- residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and ➢ With respect to all other taxes levied by the Republic of Finland, for taxes levied with respect to taxable periods beginning on or after 1 January 2021. In accordance with paragraph 9 of Article 28 and paragraph 6 of Article 29 of the MLI, paragraph 4 of Article 9 of the MLI has effect with respect to the Agreement: • In India: ➢ With respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2024; and ➢ With respect to all other taxes levied by India, for taxes levied with respect to taxable perio....