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HMRC publishes synthesised text of UK-Finland and UK-France double tax treaties as updated for the MLI

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is a multilateral treaty that enables countries to update existing treaties in accordance with its recommendations. These recommendations include measures to prevent treaty abuse, improve dispute resolution, prevent the artificial avoidance of permanent establishment status and neutralise the effects of hybrid mismatch arrangements.

The MLI came into force in the UK on 1 October 2018 and began to have effect in the UK for UK tax treaties from:

  • 1 January 2019 for taxes withheld at source;
  • 1 April 2019 for Corporation Tax; and
  • 6 April 2019 for Income Tax and Capital Gains Tax.

The MLI modifies tax treaties that the UK has signed with other countries where both countries have signed up to the MIL and agreed that the relevant treaty will be amended in accordance with the MIL. The exact date of each modification will depend on the individual treaty.

HMRC have recently published synthesised texts of the UK-Finland and UK-France double tax treaties as updated for the MLI.The modifications made by the MLI are effective in respect of the 1969 UK-Finland Double Taxation Convention and then 2008 France-UK Double Taxation Convention as follows:




Taxes withheld at source on amounts paid or credited to non-residents

1 January 2020

1 January 2019

Corporation Tax

1 April 2020

1 April 2020

Income Tax and Capital Gains Tax

6 April 2020

6 April 2020

All other taxed levied for taxable periods beginning on or after the relevant date

1 January 2020

1 July 2019


For advice on Tax matters, please contact our International and Cross Border Tax team.