Finland, France Sign DTA, Protocol

The Finnish Ministry of Finance April 4 announced the same date signing of a DTA and protocol with France, which will replace the 1970 DTA currently in force. The new DTA includes measures to: 1) prevent the double taxation of non-public service pensions; 2) allow the source country to charge a 15 percent withholding tax on portfolio dividends; 3) change the overall method of taxation from the exemption method to the credit method; and 4) set rules on the taxation of permanent establishments (PEs). The DTA complies with the OECD Model Tax Agreement and incorporates the minimum standards and recommendations ...