S.I. No. 232/1967:

DOUBLE TAXATION RELIEF (SEA OR AIR TRANSPORT) (FINLAND) ORDER, 1967.

DOUBLE TAXATION RELIEF (SEA OR AIR TRANSPORT) (FINLAND) ORDER, 1967.

WHEREAS it is enacted by section 362 of the Income Tax Act, 1967 (No. 6 of 1967), that the Government may by order confirm and give the force of law to an arrangement entered into by the Government with the government of a foreign state with a view to affording relief from double taxation in cases where income derived from the business of sea or air transport is chargeable both in the State and in the foreign state to income tax, or to any tax corresponding to income tax, or to any other tax on profits:

AND WHEREAS it is further enacted by that section that where an order is proposed to be made under that section, a draft thereof shall be laid before Dáil Éireann and the order shall not be made until a resolution approving of the draft has been passed by Dáil Éireann:

AND WHEREAS a draft of this Order has been laid before Dáil Éireann and a resolution approving of the draft has been passed by Dáil Éireann:

NOW the Government, in exercise of the powers conferred on them by section 362 of the Income Tax Act, 1967 (No. 6 of 1967), hereby order as follows:

1. This Order may be cited as the Double Taxation Relief (Sea or Air Transport) (Finland) Order, 1967.

2. The arrangement set out in the Schedule to this Order is hereby confirmed and given the force of law.

SCHEDULE

Agreement between the Government of Ireland and the Government of Finland for the avoidance of Double Taxation on Income derived from the Business of Sea and Air Transport 1965.

The Government of Ireland and the Government of Finland, desiring to conclude an agreement for the avoidance of double taxation on income derived from the business of sea and air transport, have agreed as follows:

ARTICLE I

For the purpose of this Agreement:

(a) "Irish enterprises" means the Government of Ireland, physical persons resident in Ireland and not resident in Finland, and corporations and partnerships constituted under the laws of Ireland and managed and controlled in Ireland;

(b) "Finnish enterprises" means the Government of Finland, physical persons resident in Finland and not resident in Ireland, and corporations and partnerships constituted under the laws of Finland and managed and controlled in Finland;

(c) "business of sea or air transport" means the business of transporting persons, goods, or mail carried on by the owner or charterer of ships or aircraft.

ARTICLE II

(1) All income derived from the business of sea or air transport between Ireland and other countries by Finnish enterprises engaged in such business shall be exempt from income tax and all other taxes on profits which are or may become chargeable in Ireland.

(2) All income derived from the business of sea or air transport between Finland and other countries by Irish enterprises engaged in such business shall be exempt from income tax and all other taxes on profits which are or may become chargeable in Finland.

ARTICLE III

(1) This Agreement shall be approved by each such contracting party in accordance with its legal procedure and shall enter into force on the date of exchange of notes indicating such approval, having effect in respect of income earned as from the 1st January, 1950.

(2) The exchange of notes shall take place in Helsinki as soon as possible.

ARTICLE IV

This Agreement may be terminated by either party by giving six months' notice in writing to the other party.

Done at Dublin, this 15th day of September, 1965 in duplicate.

For the Government of Ireland:

PROINSIAS MAC AOGÁIN

For the Government of Finland:

SIGURD VON NUMERS

GIVEN under the Official Seal of the Government, this 7th day of November, 1967.

SEAN Ó LOINSIGH,

Taoiseach.

EXPLANATORY NOTE

The purpose of this Order is to give the force of law in Ireland to the Agreement dated 15 September, 1965 between the Government and the Government of Finland for the avoidance of double taxation on income derived from the business of sea and air transport.