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    Tax Agreement Egypt - Finland in English

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    Tax Agreement Egypt - Finland in English

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    kyahia
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    Tax Agreement Egypt- Finland in English

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    Tax Agreement Egypt - Finland in English

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    kyahia

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    © All Rights Reserved
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    UNITED ARAB REPUBLIC MINISTRY OF TREASURY TAXATION DEPARTMENT GENERAL ADMINISTRATION OF RESEARCH CONVENTION BETWEEN THE UNITED ARAB REPUBLIC AND THE REPUBLIC OF FINLAND For the Avoidance of Double Taxation AND The Prevention of Fiscal Evasion with Respect to Taxes on Income CAIRO General Organization for Government Printing Pits 1966 CONVENTION between The Government of the Republic of Finland and The Government of the United Arab Republic for The Avoidance of Double Taxation aud the Prevention of Fiseal Evasion with Respect to Taxes on Income The Goyerament of the Republic of Finland and the Go.ernment of the United Arab Republic, Desiring to conclude a Con.ention for the a’ oidanc of double taxation and the pre ention of fiscal o aston with respect to taxcs on ‘ncome, Ha 2 agreed <8 follows (*) = CHAPTER I Scope of the Convention AnTIcce | Personal seope ‘This Conveotion shall apply to persons who are residents of one or both of the Contracting States. ARTICLE 2 Tares Covered 1.—Thiz Convention shall apply to taxes on income imposed on behalf of each Contracting State or of its subdivisions or on behalf of a public community, irrespective of the manner in which they are levied. 2.—There shail be regarded as taxes on income all taxes imposed on tolal income, or on all elements of income including taxes on gains from the alienation of movable or immovable pro- perty and taxes on the total amounts of wages or salaries paid. by enterprises. 3.—The existing taxes to which the Convelion shall apply are in particular : (a) Jn the case of Finland : (1) State income tax ; (2) Communal tax : (3) Sailors tax ; (hereinafter referred to as “Finnish tax") () Approved by Presidential Decres Me jose eee ee jo. 3677 of 196%. and shall enter into ARTICLE 4 Fiscal domicile 1.—For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the law of that State, is liable to taxation therein by reason of his domicile, tesidence, place of management or any other criterion of residence, place of management or any other criterion of a similar nature. 2.—Where by reason of the provisions of paragraph } «1 individual is a resident of both Contracting States, then this case shall be determined in accordance with the following rules : (a) He shall be deemed to be a resident of the Cont racting State in which he has a permanent home available to hin. Tf he has a permanent home available to him i both Contracting States, he shall be deemed to he 4 resident of fre Contracting State with which his personal and economic relations are closest (centre of vital in- terests) ; ' (8) If the Contracting State in which he has his centre of vital interests cannot be determined, or if he has not a Permanent home available to him in either Contracting tate, he shall be deemed to be a resident of the Contras: ting State in which he has an habitual abode - "Lf he has an Aabitual abode in both Contracting States or in neither of them. he shall be deemed to be a resideat of the Contracting State of which he is a national : (d) If he is a national of both Contracting States or of neithe: of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. 3.—Where by reason of the provisions of Paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting Stata in which its place of effective Management is situated, er ARTICLE 5 Permanent establishment 1.—For the purposes of tis Convention, the term “perma- nent establishment” means a fixed place of business in which the business of the enterprise is wholly or partly carried on, 2.—The term “ permanent establisament™ shall include evpecially : ia} @ place of management ; ti) a braneh ; fe} an office; id) a factory ; fe) a workshop ; (7) a mine, a quarry, an oilfield or other place of extraction of natural resources : ig) a@ farm, a plantation and a warehouse ; {A}, a building site or construction or assembly project which exists for more taan six months. 3.—The term “permanent establishment” shall not be deemed to inelude = {a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging tc the enterprise ; (4) the maintenance of a stock of goods or merchandise be. longing to the enterprise solely for the purpose of storage, display or delivery ; {cl the maintenance of a stock of goods or merchandise be- longing to the enterprise solely for tne purpose of pro- ceasing by another enterprise : {@) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or for collecting information, for the enterprise ; a— as aforesaid, tie profits of the enterprise may be taxi—in the other State but only so much of them as is attributable to that permanent establishment. 2.—Where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate ise engaged in the same or similar activities under tae came r conditions and dealing wholly independently with the enterprise of which it is a permanent establishment, 3.—In the determination of the profits of a permanent establishment. there shall be allowed as deductions expenses which are incurred for the purpose of the permanent establishment including executive and general administrative expenses +0 incurred, whether in the State in which the permanent establishment is situated or elsewhere. t.—Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establich- ment on the basis of an apportionment of the total profits of th- enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary ; tae method of appertionment adopted shall, however, be such that the result shal! be in accordance with the principles laid down in this Article. 5.—No profits shall be attributed to a permanent establi-':nie1t by reason of the mere purchase by that permanent establishment of goods or merchandise for tae enterprise. 6.—For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary. 7.—Where profits include items of income waich are dealt with separately in other Articles of this Convention, then the provisions of these Articles shall not be affected by the provisions of the present Article. —F— ARTICLE 8 Shipping and air transport 1,—Profits from the operation of ships or aircraft in inter. national traffic shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 2.—The provisions of paragraph 1 shall likewise apply in Tespect of participations in pools of any kind by Finnish or United Arab Republic enterprises engaged in shipping or air transport. 3.—Where profits as referred to in this Article are derived by a company which is a resident of a Contracting State, dividends paid by the company to persons which are not resident in the other Contracting State, shall be exempt from tax in that other State. ARTICLE 9 Associated enterprises 1— Where (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or. (6) The same persons participate directly or indirectly in the management, control or capital of an enterprise of a ing State and an enterprise of the other Contracting State, and in either case conditions ace made or imposed two enterprises in their commercial or financial relations which differ from those which would he made between independent enterprises, then any profits which would, bur for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not 80 accrued, may be included in the profits of that enterprise and taxed accordingly. _ 10 — 2.—If the information available to the taxx

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