ARTICLE 24 Non-discrimination 　　1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected. This provision shall also apply to persons who are not residents of one or both of the Contracting States. However, for the purposes of United States tax, an individual who is a United States national and who is not a resident of the United States and an individual who is a national of Finland and who is not a resident of the United States are not in the same circumstances. 　　2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. Nothing in this Article shall be construed as obliging a Contracting State to grant to a resident of the other Contracting State the right to deduct from the profits attributable to a permanent establishment of that resident situated in the first-mentioned State any portion of the amount of any dividends paid by that resident. 　　3. Except where the provisions of paragraph 1 of Article 9 (Associated Enterprises), paragraph 5 of Article 11 (Interest), or paragraph 6 of Article 12 (Royalties) apply, interest, royalties, and other disbursements paid by a resident of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of the first-mentioned resident, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debts of a resident of a Contracting State to a resident of the other Contracting State shall, for the purposes of determining the taxable capital of the first-mentioned resident, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 　　4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the firstmentioned State are or may be subjected. 　　5. Nothing in this Article shall be construed as preventing either Contracting State from imposing the tax described in paragraph 6 of Article 10 (Dividends). 　　6. The provisions of this Article shall, notwithstanding the provisions of Article 2 (Taxes Covered), apply to taxes of every kind and description imposed by a Contracting State or a political subdivision, statutory body, or local authority thereof. ARTICLE 25 Mutual Agreement Procedure 　　1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or national. 　　2. The competent authority shall endeavor, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Convention. Any agreement reached in accordance with the preceding paragraph shall be implemented notwithstanding any time limits or other procedural limitations in the domestic law of the Contracting States, provided that the competent authority of the Contracting State requested to provide a refund has received notification that such a case exists within six years from the end of the taxable year to which the case relates. 　　3. The competent authorities of the Contracting States shall endeavor to resolve by mutual　agreement any difficulties or doubts arising as to the interpretation or application of the Convention. In particular, the competent authorities of the Contracting States may agree a) to the same attribution of income, deductions, credits, or allowances of an enterprise of a Contracting State to its permanent establishment situated in the other Contracting State; 　　b) to the same allocation of income, deductions, credits, or allowances between persons; 　　c) to the same characterization of particular items of income; 　　d) to the same application of source rules with respect to particular items of income; 　　e) to a common meaning of a term; 　　f) to increases in any specific amounts referred to in the Convention to reflect economic or monetary developments; and 　　g) to the application of the provisions of domestic law regarding interest on deficiencies and refunds and non-criminal penalties and fines, in a manner consistent with the purposes of the Convention. 　　They may also consult together for the elimination of double taxation in cases not provided for in the Convention. 　　4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. ARTICLE 26 Exchange of Information 　　1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Article 1 (Personal Scope). Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment, collection, or administration of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 　　2. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: 　　a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; 　　b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; 　　c) to supply information which would disclose any trade, business, industrial, commercial, or professional secret or trade process, or information, the disclosure of which would be contrary to public policy. 　　3. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall obtain the information to which the request relates in the same manner and to the same extent as if the tax of the first-mentioned State were the tax of that other State and were being imposed by that other State. If specifically requested by the competent authority of a Contracting State, the competent authority of the other Contracting State shall provide information under this Article in the form of depositions of witnesses and authenticated copies of unedited original documents (including books, papers, statements, records, accounts, and writings), to the same extent such depositions and documents can be obtained under the laws and administrative practices of that other State with respect to its own taxes. 　　4. Each of the Contracting States shall endeavor to collect on behalf of the other Contracting State such amounts as may be necessary to ensure that relief granted by the Convention from taxation imposed by that other State does not inure to the benefit of persons not entitled thereto. 　　5. Paragraph 4 shall not impose upon either of the Contracting States the obligation to carry out administrative measures which are of a different nature from those used in the collection of its own taxes, or which would be contrary to its sovereignty, security, or public policy. 　　6. For the purposes of this Article, the Convention shall apply, notwithstanding the provisions of Article 2 (Taxes Covered), to taxes of every kind imposed by a Contracting State. ARTICLE 27 Members of Diplomatic Missions and Consular Posts 　　Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements. ARTICLE 28 Entry into Force 　　1. This Convention shall be subject to ratification, acceptance, or approval in accordance with the applicable procedures of each Contracting State. The Governments of the Contracting States shall notify each other as soon as possible that those procedures have been complied with. 　　2. The Convention shall enter into force thirty days after the date of the later of the notifications referred to in paragraph 1, and its provisions shall have effect: 　　　a) in Finland: 　　(i) in respect of taxes withheld at source, on income derived on or after 1 January in the calendar year next following the year in which the Convention enters into force; 　　(ii) in respect of other taxes on income and taxes on capital, for taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the Convention enters into force; 　　b) in the United States: 　　(i) in respect of taxes withheld at source, for amounts paid or credited on or after the first day of the second month next following the date on which the Convention enters into force; 　　(ii) in respect of other taxes, for taxable years beginning on or after the first day of January next following the date on which the Convention enters into force. 　　3. The Convention between the Republic of Finland and the United States of America with respect　to taxes on income and property, signed at Washington on 6 March 1970, (hereinafter referred to as "the 1970 Convention"), shall cease to have effect with respect to taxes to which the Convention applies in accordance with the provisions of paragraph 2. The 1970 Convention shall terminate on the last date on which it has effect in accordance with the foregoing provision of this paragraph. ARTICLE 29 Termination 　　This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year following after the period of five years from the date on which the Convention enters into force. In such event, the Convention shall cease to have effect: 　　a) in Finland: 　　(i) in respect of taxes withheld at source, on income derived on or after 1 January in the calendar year next following the year in which the notice is given; 　　(ii) in respect of other taxes on income and taxes on capital, for taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following the year in which the notice is given; 　　b) in the United States: (i) in respect of taxes withheld at source, for amounts paid or credited on or after the first day of January next following the expiration of the 6-months period; 　　(ii) in respect of other taxes, for taxable years beginning on or after the first day of January next following the expiration of the 6-months period. 　　IN WITNESS WHEREOF, the undersigned, being duly authorized thereto, have signed this Convention. 　　DONE in Helsinki, in duplicate in the English and Finnish languages, both texts being equally authentic, this 21st day of September 1989. FOR THE GOVERNMENT OF THE FOR THE GOVERNMENT OF THE UNITED STATES OF AMERICA: REPUBLIC OF FINLAND: (s) Michael Durkee (s) Ulla Puolanne