Canada-Finland Tax Convention Act, 2006

Here is a summarized version of the template:

Article 5: Permanent Establishment

• A permanent establishment is defined as a fixed place of business through which the business of an enterprise is wholly or partly carried on.
• It includes places like management, branches, offices, factories, workshops, and mines.

Article 6: Income from Immovable Property

• Income from immovable property (including income from agriculture or forestry) situated in another Contracting State may be taxed in that other State.
• The term "immovable property" includes land, buildings, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property, and rights to variable or fixed payments as consideration for the working of mineral deposits.

Article 7: Business Profits

• The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.
• If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment.

Article 8: Shipping and Air Transport

• Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
• However, profits derived from the operation of ships used principally to transport passengers or goods exclusively between places in a Contracting State may be taxed in that State.

Article 9: Associated Enterprises

• Where an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, and conditions are made or imposed which differ from those which would be made between independent enterprises, then any profits which would have accrued to one of the enterprises may be included in the profits of that enterprise and taxed accordingly.

Article 10: Dividends

• Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.
• However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident, and according to the laws of that State.