Malliverosopimukseen

Malliverosopimukseen refers to the OECD Model Tax Convention on Income and on Capital, a template used by many countries when negotiating bilateral tax treaties. It provides a standardized framework for allocating taxing rights between jurisdictions and for preventing double taxation and tax evasion. Although the model itself is not a binding treaty, many countries base their agreements on its provisions, with country-specific modifications.

The model covers core elements of international tax rules. Key topics include residency, permanent establishment, business profits, and the taxation of cross-border income such as dividends, interest, and royalties. It also addresses capital gains, methods for eliminating double taxation (usually through exemption or credit), and non-discrimination between residents and nationals of treaty partner states. In addition, it outlines dispute resolution mechanisms, notably the mutual agreement procedure, and contains provisions on information exchange, assistance in tax collection, and general anti-abuse rules to counter treaty shopping and other BEPS-related concerns.

Historically, the OECD Model was first published in 1963 and has been revised several times to reflect evolving international tax norms. Revisions have incorporated BEPS actions and other reforms, and a separate Multilateral Instrument enables many of these changes to modify existing treaties efficiently. The model thus serves as a common reference point for treaty negotiations and for interpreting treaty rights and obligations across jurisdictions.

In Finland, the term malliverosopimukseen is used in reference to the OECD model as the standard for drafting and interpreting Finnish tax treaties. The Finnish tax framework relies on this model when negotiating bilateral agreements and applying treaty provisions in practice. See also OECD Model Tax Convention, bilateral tax treaties, BEPS, and the Multilateral Instrument.