Agreement between the Republic of Finland and the United Mexican States for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
| Coming into Force | 14 July 1998 |
| Citation | UNTS v. 2124 (p.295) |
| Date of Conclusion | 12 February 1997 |
| Registration Date | 20 November 2000 |
| Registration Number | 37029 |
| Subject Terms | Taxation |
| Type of Document | Bilateral |
| Participants | Finlandia,México |
| Party Submitting the Application for Registration | Finland |
No.
37029
Finland
and
Mexico
Agreement
between
the Republic
of
Finland
and the
United
Mexican
States for
the
avoidance
of
double
taxation
and the
prevention
of
fiscal
evasion
with
respect
to
taxes on
income.
Mexico
City,
12
February
1997
Entry
into
force:
14
July
1998,
in
accordance
with
article
27
Authentic
texts:
English, Finnish
and
Spanish
Registration
with
the
Secretariat
of
the United
Nations:
Finland,
20 November
2000
Finlande
et
Mexique
Accord
entre
la
Ripublique
de
Finlande
et
les
Etats-Unis du
Mexique
tendant
a
6viter
la
double imposition
et
i
pr~venir
l'6vasion
fiscale
en
matiire
d'imp6ts
sur
le
revenu.
Mexico,
12
f~vrier
1997
Entree
en
vigueur
:
14juillet
1998,
conformgment
h
Particle
27
Textes
authentiques
:
anglais,finnois
et
espagnol
Enregistrement
aupris
du
Secretariat
des
Nations
Unies :
Finlande,
20 novembre
2000
Volume
2124,
1-37029
[ENGLISH
TEXT
-
TEXTE
ANGLAIS 3
AGREEMENT BETWEEN
THE
REPUBLIC
OF
FINLAND
AND THE
UNITED
MEXICAN
STATES FOR
THE
AVOIDANCE
OF
DOUBLE
TAXATION
AND THE
PREVENTION
OF
FISCAL EVASION
WITH
RESPECT
TO
TAXES
ON
INCOME
The
Government
of
the
Republic
of
Finland
and
the
Government
of
the
United
Mexi-
can
States,
Desiring,
to
conclude
an
Agreement for
the
avoidance
of
double
taxation and
the
pre-
vention
of
fiscal
evasion with
respect
to
taxes on income,
Have
agreed
as
follows:
Article
1.
Personal
scope
This
Agreement
shall
apply
to
persons
who are
residents
of
one
or
both
of
the
Con-
tracting
States.
Article
2.
Taxes
covered
1.
This
Agreement
shall apply
to
taxes
on
income
imposed
on
behalf
of
a
Contracting
State or
of
its
political
subdivisions
or
local
authorities,
irrespective
of
the
manner
in
which
they
are
levied.
2.
There
shall be
regarded
as
taxes
on income
all
taxes imposed
on
total
income, or
on
elements
of
income, including
taxes
on
gains
from
the
alienation
of
movable or
immovable
property,
as
well
as
taxes
on capital
appreciation.
3.
The
existing
taxes
to
which
this
Agreement
shall apply
are:
a)
in
Mexico:
(i)
the
income
tax
(el
impuesto
sobre
la
renta);
and
(ii)
the
assets
tax (el
impuesto
al
activo);
(hereinafter
referred
to
as
"Mexican
tax");
b) in
Finland:
(i)
the
state
income
taxes
(valtion
tuloverot;
de
statliga
inkomstskattema);
(ii)
the
corporate
income
tax
(yhteis6jen tulovero;
inkomstskatten
f6r
samfund);
(iii)
the
communal
tax
(kunnallisvero;
kommunalskatten);
(iv)
the
tax
withheld
at
source
from
interest
(korkotulon
ldhdevero;
killskatten
pA
riinteinkomst);
and
(v)
the tax
withheld
at source
from
non-residents' income
(rajoitetusti verovelvollisen
liihdevero;
killskatten
f'r
begr~insat
skattskyldig);
hereinafter
referred
to
as
"Finnish
tax").
Volume
2124,
1-3
7029
4.
This
Agreement
shall
apply also
to
any
identical
or
substantially
similar
taxes
which
are
imposed
after
the
date
of
signature
of
the
Agreement
in
addition
to,
or
in
place
of,
the
existing
taxes.
The
competent
authorities
of
the
Contracting
States shall
notify
each
other
of
any
significant
changes
which
have
been
made
in
their
respective
taxation
laws.
Article
3.
General
definitions
1. For
the
purposes
of
this
Agreement,
unless
the
context otherwise requires:
a)
the
term
"Mexico"
means
the
United
Mexican
States;
when
used
in a
geographical
sense,
it
means
Mexico
as
defined
in
the
Federal
Fiscal Code;
b)
the
term
"Finland"
means
the
Republic
of
Finland
and, when
used
in
a
geographical
sense,
means
the
territory
in
which
the tax
laws
of
the
Republic
of
Finland
are
effective;
c)
the terms
"a
Contracting
State "and "the other
Contracting
State"
mean Mexico
or
Finland,
as
the
context requires;
d)
the
term
"person"
includes
an
individual,
a
company
and any
other
body
of
persons;
e)
the
term
"company" means
any
body
corporate
or
any
entity which
is
treated
as
a
body
corporate
for
tax
purposes;
f)
the terms "enterprise
of
a
Contracting
State"
and "enterprise
of
the
other
Contracting
State"
mean respectively
an
enterprise carried
on
by
a
resident
of
a
Contracting
State
and
an
enterprise carried
on by
a
resident
of
the
other Contracting
State;
g)
the
term "international
traffic"
means any transport
by
a
ship
or
aircraft operated
by
an
enterprise
of
a
Contracting
State,
except
when
the
ship
or
aircraft
is
operated solely
be-
tween
places in
the
other Contracting
State;
h)
the
term
"national" means:
(i)
any individual
possessing
the
nationality
of
a
Contracting
State;
ii)
any
legal
person, partnership
or
association
deriving
its
status
as
such
from
the laws
in
force
in
a
Contracting
State;
i)
the
term
"competent
authority"
means:
(i)
in
Mexico,
the
Ministry
of
Finance
and Public
Credit;
(ii) in
Finland,
the
Ministry
of
Finance,
its
authorised representative
or
the
authority
which,
by
the
Ministry
of
Finance,
is
designated
as
competent
authority.
2.
As
regards
the
application
of
this
Agreement
by
a
Contracting
State
any term
not
defined therein
shall,
unless
the
context
otherwise
requires,
have
the
meaning which
it has
under
the
law
of
that
State
concerning
the
taxes
to
which
the
Agreement
applies.
Article
4.
Residence
1. For
the
purposes
of
this
Agreement,
the
term
"resident
of
a
Contracting
State"
means
any
person
who,
under
the laws
of
that
State,
is
liable
to tax
therein
by
reason
of
his domi-
cile,
residence,
place
of
management,
place
of
incorporation
(registration)
or
any
other
cri-
terion
of
a
similar
nature.
However,
the
term
does
not
include
any
person
who
is
liable to
tax
in that
State
in
respect only
of
income
from
sources
in
that
State.
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