1984421565

358 United Nations — Treaty Series 1972

[Translation — Traduction]

No. 7160. AGREEMENT BETWEEN THE REPUBLIC OF FINLAND AND THE REPUBLIC OF AUSTRIA FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND FORTUNE. SIGNED AT YIENNA ON 8 OCTOBER 1963¹

PrOTOCOL^{2 3} AMENDING THE ABOVE-MENTIONED AGREEMENT. SlGNED AT VlENNA ON

21 September 1970

Authentic texts: Finnish and German.

Registered by Finland on 10 Marek 1972.

The President of the Republic of Finland and the Federal President of the Republic of Austria, desiring to conclude a protocol amending the Agreement for the avoidance of double taxation with respect to taxes on income and fortunę (hereinafter referred to as “ the Agreement ”), signed by the Contracting Parties at Vienna on 8 October 1963,³ have for that purpose appointed as their plenipotentiaries :

The President of the Republic of Finland :

Mr. Jussi Makinen, Ambassador Extraordinary and Plenipotentiary of the Republic of Finland at Vienna;

The Federal President of the Republic of Austria :

Dr. Josef Hammerschmidt, Chief of Section in the Federal Ministry of Finance,

who, having exchanged their fuli powers, found in good and due form, have agreed as follows :

Article 1

Amendments to the Agreement

1. Article 9 of the Agreement shall be amended to read as follows :

“ Article 9

“ 1. Dividends paid by a company domiciled in one of the Contracting States to a person domiciled in the other Contracting State shall be subject to taxation in that other State.

“ 2. However, such dividends may be taxed in the Contracting State in which the company paying the dividends is domiciled, and according to the law of that State, but the tax so charged shall not exceed 10 per cent of the gross amount of the dividends.

United Nations, Treaty Series, vol. 490, p. 255, and annex A in volume 525.

Came into force on 25 February 1972, i.e. 30 days after the exchange of the instruments of ratification, which took place at Helsinki on 26 January 1972, in accordance with article 2.

United Nations, Treaty Series, vol. 490, p. 255.