July 14, 2023
Ministry of Finance
Measures to Prevent BEPS applicable to Tax Treaties will be Increased
[ Finland ]
[Provisional translation]
1. According to the publication as of June 27, 2023 by the Secretary-General of the Organisation for Economic Co-operation and Development (OECD) acting as the Depositary of the "Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting" (Convention to Implement Measures to Prevent BEPS), Finland submitted a notification for updating the list of the existing reservations and notifications. Accordingly, the provisions of paragraph 4 of Article 9 of this Convention will newly apply to the tax treaty between Japan and Finland.
2. The notification submitted by Finland on June 27, 2023 shall take effect with respect to the tax treaty between Japan and Finland:
(a) for reservations and notifications in respect of provisions relating to taxes withheld at source, where the event giving rise to such taxes occurs on or after January 1, 2024; and
(b) for reservations and notifications in respect of all other provisions, for taxes levied with respect to taxable periods beginning on or after January 1, 2024.
3. For the details of the application of this Convention to the tax treaty between Japan and Finland, see the webpage below.
◆The text of the Convention to Implement Measures to Prevent BEPS
“Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting”（Japanese(PDF:997KB)
・English(PDF:269KB) ）
“Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting”（Japanese(PDF:997KB)
・English(PDF:269KB) ） ◆Convention to Implement Measures to Prevent BEPS (MLI)
└List of Reservations and Notifications of Japan（Japanese(PDF:462KB)・English(PDF:290KB)）
└Application of the MLI to Japan's Tax Treaties
└List of Reservations and Notifications of Japan（Japanese(PDF:462KB)
・English(PDF:290KB)） └Application of the MLI to Japan's Tax Treaties