author_orbitax
Orbitax

Share This Article

Finland Publishes Notification on Triggering of Royalties MFN Clause in Tax Treaty with Latvia

07 April 2021

|

Treaty Development

|

Finland-Latvia

Finland has published Notification No. 15/2021 of 3 March 2021, which includes that the MFN clause contained in paragraph 7 of Article 12 (Royalties) of the 1993 tax treaty with Latvia has been triggered with effect from 1 January 2018. As a result, the following provisions apply: Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other Contracting State (i.e., exempt from withholding tax); and The term "royalties" as used in Article 12 means payments of any kind received as a consideration for the use of,...