Dual residence conflicts and the elimination of international double taxation in Finland

A dual residence conflict may arise where a Finnish national who resided in Finland moves abroad, but does not break all his substantial ties with Finland. According to the three-year rule in Finland, the Finnish national will be treated, for Finnish tax purposes, as a Finnish resident and subject to unlimited tax liability in Finland in the year of emigration and the three subsequent years. The new state of residence will also treat the taxpayer, for its tax purposes, as a resident of that state from the time of immigration. This article examines the extent to which Finland eliminates international double taxation in these cases in both non-treaty and treaty situations.