Protocol

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..... vention of fiscal evasion with respect to taxes on income, the undersigned have agreed that the following provisions shall form an integral part of the Agreement: I. Ad Articles 5 and 6 Under Finnish taxation law income from agriculture or forestry is treated as income from immovable property. Accordingly, income from agriculture or forestry carried on in Finland shall, in the case of Finland, for .....

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..... s) to a rate lower than that provided for in paragraph 2 of Article 10 or paragraph 2 of Article 11 or paragraph 2 of Article 12 of the Agreement, such exemption or lower rate shall be made applicable to the dividends, interest, royalties or fees for technical services (either generally or in respect of those specific categories of dividends, interest, royalties or fees for technical services) ari .....

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..... ority thereof, has an interest. IN WITNESS whereof the undersigned, duly authorized thereto, have signed this Protocol. DONE in duplicate at New Delhi this 15th day of January, 2010, in the Finnish, Swedish, Hindi and English languages, all four texts being equally authentic. In the case of divergence of interpretation, the English text shall prevail. For the Government of For the Government of th .....

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