The France-Finland tax treaty: the 1970 text and the 2023 text, side by side

Two official sources do not refer to the same text. The French list of conventions (April 29, 2026, agreements in force as of January 1, 2026) includes the convention of September 11, 1970. The Finnish tax authorities (list updated on September 1, 2026) include a convention "34/2026" and classify the text published under number 8/1972 as "no longer in force." Finnish decree no. 34/2026 sets the convention's entry into force from April 4, 2023, to August 28, 2026, while the "International Conventions" page on impots.gouv.fr presents it as signed on April 4, 2023, and not yet in force. This page does not definitively resolve the issue: it presents the sources, then the two texts article by article. For a given year, the text applicable to your situation should be verified before making any decision.

Two sources, two texts

This page does not cite any French publications regarding the entry into force of the 2023 convention. Article 29 of this text provides for entry into force on the thirtieth day following the last notification. It applies withholding tax, on the Finnish side, to income received from January 1st of the following calendar year, and on the French side, to amounts taxable after the calendar year of entry into force. For other income taxes, it applies to tax years beginning on that date on the Finnish side and to income relating to a calendar year or fiscal year beginning after the year of entry into force on the French side. Paragraph 3 specifies that the 1970 convention "shall cease to have effect" for the taxes concerned, and will end on the date on which it is last applicable. For the 1970 text, French sources also differ on the effective date: February 1, 1972 according to the BOFiP (Official Bulletin of Public Finances), March 1, 1972 according to the header of the texts published on impots.gouv.fr. This discrepancy is not resolved here; it should be verified with the tax authorities.

Maximum deductions and key rules

Who is a resident?

Both texts establish the same order for a natural person resident in both States: the permanent home, then, if there is one in each State, the center of vital interests; failing that, the habitual residence; then nationality; and finally, the agreement of the competent authorities. This is Article 4, paragraph 2, in both cases.

Dividends: from the tax credit to the 15% ceiling (%)

In the 1970 text, dividends are taxable only in the beneficiary's state of residence (Article 10 § 1). Paragraph 3 provides for certain Finnish residents a payment equal to the tax credit, less a tax of 15 %, and paragraph 4 allows a Finnish resident to claim a refund of the withholding tax.

In the 2023 text, the state of origin of the company may tax dividends up to a limit of 0 or 15 (Article 10, paragraph 2). Paragraph 6 addresses dividends paid from income or gains derived from real estate by certain investment vehicles that distribute the bulk of their income each year and whose real estate income is exempt from tax. The state of origin may tax these dividends at a rate of up to 15 if the beneficial owner, a resident of the other state, directly or indirectly holds less than 10 of the vehicle's capital; at 10 or more, they are taxed at the rate provided for by the national legislation of the state from which they originate.

Interest: 10 % or no withholding

The 1970 legislation authorizes the source state to tax interest, up to a maximum of 10%. Paragraph 3 excludes this tax for interest paid under loan or deferred payment agreements related to sales of industrial, commercial, or scientific equipment, or the construction of industrial, commercial, or scientific facilities or public works; for interest on any type of loan granted by a banking institution; and for interest paid as compensation for late payment, following a formal demand or legal action, on a debt for which no interest had been stipulated. The BOFiP (French Official Tax Bulletin) guidance adds form 5000 and its appendices 5001 to 5003. The 2023 legislation reserves the tax on interest for the state of residence of the beneficial owner.

Pensions and the elimination of double taxation

The 1970 legislation provides, for France, for the exemption of income taxable in Finland, except for a tax credit under Articles 11, 16, and 17; and for Finland, for the exemption of income and assets taxable in France, except for a credit under Articles 10, 11, 16, and 17 (Article 23). In both cases, the tax may be calculated by reference to the total amount of taxable income according to the legislation of the state concerned.

The 2023 text uses tax credits (Article 21). Finland deducts French tax paid and exempts dividends paid by a French company to a Finnish company that directly controls at least 10% of the voting rights. France grants a tax credit against French tax. This credit is equal to the tax paid in Finland, up to the limit of the corresponding French tax, for income covered by Articles 7 and 13 § 2 (income subject to corporate income tax), Article 10, Article 13 §§ 1 and 4, Article 14 § 3, Article 15, and Article 16 §§ 1 and 2. For income not covered by this list, it is equal to the corresponding French tax, provided that the beneficiary resident in France is subject to Finnish tax on this income. Article 21 § 3 provides for a deduction for pensions taxable at source under Article 17 § 2, that is to say when the contributions were deductible, when those of the employer were not taxable or when the pension falls under the social security of the paying State.

Inheritance and gift

The French list includes, in addition to the 1970 convention, the convention of August 25, 1958, on inheritance tax (column "S"). According to the BOFiP (Official Bulletin of Public Finances), this convention applies to the estates of individuals whose last tax domicile was in France or Finland, and real estate is taxable only in the country where it is located. The 2023 text only addresses income tax. The cited sources do not specify the status of the 1958 convention on inheritance tax. Article 30, paragraph 3, of the 1970 text, for its part, terminates a convention of August 25, 1958, concerning taxes on income and capital; this page does not clarify the relationship between these two references.

A refusal of benefits in both texts

The consolidated version of the 1970 text includes a provision in the CML (Common Market Law): an advantage is denied if obtaining it was one of the main objectives of an arrangement or transaction, unless it is consistent with the object and purpose of the agreement. The 2023 text contains the same rule in Article 27.

Interest of €10,000: a numerical example (fictitious profile)

Situation. Pierre, a fictitious profile, has left France and is a resident of Finland within the meaning of Article 4. He has lent money to an individual resident of France (outside the three cases of Article 11 § 3 of the 1970 text) and receives €10,000 in interest, as well as €20,000 in dividends from a French company (assumed amounts).

Issue. He wants to know what France can collect according to each of the two texts.

Strategy. He reads article 11 of each text, then article 10.

Result. 1970 text: withholding tax of up to €1,000 on interest (10 %), i.e., €9,000 net; dividends exempt from withholding tax in France, under certain conditions, according to the BOFiP (Official Tax Bulletin). 2023 text: no contractual withholding tax on interest, i.e., €10,000; contractual ceiling of €3,000 (15 %) on dividends. These figures are contractual ceilings, not the French domestic tax rate, which this page does not address.

What this page does not cover

It does not detail the other articles of the two texts, nor the 2023 protocol. It does not specify which of the two texts applies to a given year. Finnish law is validated by a local professional.

What changes depending on your situation

• The tax year and the date the income was received.
• Your residence as defined in Article 4.
• The nature of the income: dividend, interest, gain, salary, pension.
• The percentage of capital held and the holding period.
• The location of the assets, particularly real estate, and the nature of the company held.

The rule depends on your situation. No results are guaranteed.