According to Vero, the France–Finland treaty will apply from 1 January 2027, following its entry into force on 28 August 2026. For a Finnish non-government pension paid to a French resident, article 17 permits taxation in Finland where personal contributions were deductible there, employer contributions were not taxable there for the recipient, or the pension falls under its social security legislation.
Double taxation is then eliminated through a reverse credit: Finland takes French tax into account when calculating its own tax. The pension's Finnish origin therefore does not remove the need to examine the conditions in article 17 and the treatment of contributions.
To prepare for the change, the file should bring together the dates on which pension payments began, proof of residence and information about how the pension was funded. Two retirees now receiving the same type of income may be treated differently because of their position on the signature date. Continuity of residence must also be examined over time. The amount actually due then requires reconciling taxation in both States; the announced reverse credit does not determine an individual's result on its own.
Article 29, paragraph 4, preserves exclusive taxation in France for pensions already received on 4 April 2023 by a French resident, where they were then exclusively taxable there under the 1970 treaty. Protection continues only while French residence remains uninterrupted. Taking up residence or bringing a pension into payment later, or subsequently leaving France, does not allow that protection to be presumed.