Finnish investment fund dividend to non-resident not covered by tax treaties on double taxation avoidance.

The Supreme Administrative Court dismissed the applicant's request for a preliminary ruling regarding the tax status of a dividend. The applicant argued that the annual profit share paid by a Finnish investment fund to a non-resident resident in Sweden or Canada constituted an 'interest' under relevant tax treaties. The court determined that the specific nature of the payment did not fall within the definitions of 'interest' or 'dividend' in the applicable treaties between Finland and Sweden or Canada. Consequently, the court ruled that the payment was not covered by the tax treaty provisions cited.