Skip to main content
Version status: | Document consolidation status: No known changes
Version date: 21 September 1993 - onwards

Explanatory Note

This Order gives the force of law in Ireland to the Agreement with the Republic of Finland set out in the Schedule to the Order.

The Agreement provides for the allocation of taxing rights between Ireland and the Republic of Finland and for the granting of relief from double taxation with regard to items of income and capital gains which, under the laws of Ireland and the laws of Denmark, may be taxed in both countries.

For example, items such as business profits, interest, royalties and gains on movable property not arising through or connected with a permanent establishment in the source country, profits from the operation of ships or aircraft in international traffic and non-government pensions are taxable only in the country of residence of the recipient. On the other hand, remuneration in respect of services rendered to a government of one of the countries is normally taxable only in that country, i.e. the country of source.

Where both countries continue to have taxing rights, for example, with regard to business profits arising through a permanent establishment which an enterprise of one country has in the other country or dividends received in one country from the other country, the Agreement provides that the country of residence of the recipient will allow a credit against its own tax for the tax imposed on the same income by the country of source. Thus double taxation is relieved.

Rentals received by an Irish enterprise in respect of the leasing of aircraft or ships which are in use in international traffic will be exempt from Finnish tax, in particular Finnish withholding tax.