On December 28, 2018 the Government of the Hong Kong Special Administrative Region issued a press release announcing that the Agreement between the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and the Government of the Republic of Finland for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (which was signed on May 24, 2018) (Hereafter: the DTA) will enter into force on December 30, 2018.

 

Based on Article 28, Paragraph 2 of the DTA (“Entry into Force”) the fact that the DTA will enter into force on December 30, 2018 means that the provisions of the DTA shall have effect:

(a)  in the Hong Kong Special Administrative Region:

      in respect of Hong Kong Special Administrative Region tax, for any year of assessment beginning on or after April 1, 2019;

(b)  in Finland:

(i)   in respect of taxes withheld at source, on income derived on or after January 1, 2019;

(ii)  in respect of other taxes on income for taxes chargeable for any tax year beginning on or after January 1, 2019.

 

Article 28, Paragraph 3 of the DTA arranges that the Agreement between the Hong Kong Special Administrative Region of the People’s Republic of China and the Republic of Finland for the Avoidance of Double Taxation with respect to Taxes on Income from Aircraft Operation signed in Hong Kong on 19 November 2007 (hereinafter referred to as “the 2007 Agreement”) shall cease to have effect with respect to taxes to which this Agreement applies in accordance with the provisions of Article 28, Paragraph 2. The 2007 Agreement shall terminate on the last date on which it has effect in accordance with the foregoing provision of this paragraph.

 

An analysis of a further selection of provisions included in the DTA can be found in our article from May 27, 2018. In that article you can also find links to the text of the DTA as available on the website of the Government of the Hong Kong Special Administrative Region.

 

 

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