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Article 30 - Termination - FinlandExtract Article 30 Termination This Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year following after the period of five years from the date on which the Agreement enters into force. In such event, the Agreement shall cease to have effect: a) in Finland: (i) in respect of taxes withheld at source, on income derived on or after 1st January in the calendar year next following the year in which the notice is given; (ii) in respect of other taxes on income for taxes chargeable for any tax year beginning on or after 1st January in the calendar year next following the year in which the notice is given; b) in India: (i) in respect of taxes withheld at source, for amounts paid or credited on or after 1st April of the calendar year next following that in which the notice is given; (ii) in respect of taxes on income, for any fiscal year beginning on or after 1st April of the calendar year next following that in which the notice is given. In witness whereof the undersigned, duly authorised thereto, have signed this Agreement. Done in duplicate at NEW DELHI this 15th day of January, 2010, in the Finnish, Swedish, Hindi and English languages, all four texts being equally authentic. In the case of divergence of interpretation, the English text shall prevail. For the Government of the Republic of India For the Government of the Republic of Finland (S.S.N. MOORTHY) CHAIRMAN CENTRAL BOARD OF DIRECT TAXES (TERHI HAKALA) AMBASSADOR OF FINLAND TO INDIA PROTOCOL to the Agreement between The Republic of India and The Republic of Finland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income At the moment of signing of the Agreement between the Republic of Finland and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Agreement: I. ad Articles 5 and 6 Under Finnish taxation law income from agriculture or forestry is treated as income from immovable property. Accordingly, income from agriculture or forestry carried on in Finland shall, in the case of Finland, for the purposes of the Agreement be treated as income from immovable property referred to in Article 6 of the Agreement. II. ad Articles 10,11 and 12 It is agreed that if after coming into force of this Agreement, any agreement or convention between India and a Member State of the Organisation for Economic Cooperation and Development provides that India shall exempt from tax dividends, interest, royalties or fees for technical services (either generally or in respect of specific categories of dividends, interest, royalties or fees for technical services) arising in India, or limit the tax charged in India on such dividends, interest, royalties or fees for technical services (either generally or in respect of specific categories of dividends, interest, royalties or fees for technical services) to a rate lower than that provided for in paragraph 2 of Article 10 or paragraph 2 of Article 11 or paragraph 2 of Article 12 of the Agreement, such exemption or lower rate shall be made applicable to the dividends, interest, royalties or fees for technical services (either generally or in respect of those specific categories of dividends, interest, royalties or fees for technical services) arising in India and beneficially owned by a resident of Finland and dividend, interest, royalties or fees for technical services arising in Finland and beneficially owned by a resident of India under the same conditions as it such exemption or lower rate had been specified in those paragraphs. The competent authority of India shall inform the competent authority of Finland without delay that the conditions for the application of this paragraph have been met and issue a notification to this effect for application of such exemption or lower rate. With reference to the all text it is understood that the term "statutory body" used in this Agreement means any legal entity of a public character created by the laws of a Contracting State in which no person other than the State itself, or a local authority thereof, has an interest. IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol. Done in duplicate at NEW DELHI this 15th day of January, 2010, in the Finnish, Swedish, Hindi and English languages, all four texts being equally authentic. In the case of divergence of interpretation, the English text shall prevail. For the Government of the Republic of India For the Government of The Republic of Finland (S.S.N. MOORTHY) CHAIRMAN CENTRAL BOARD OF DIRECT TAXES (TERHI HAKALA) AMBASSADOR OF FINLAND TO INDIA
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