the king by his prerogative is discharged from all tithes. So a vicar shall pay no tithes to the rector, nor the rector to the vicar, for ecclesia decimas non-folvit ecclesiae. But these personal to both the king and the clergy; for their tenant or lessee shall pay tithes of the same land, though in their own occupation it is not tithable. And, generally speaking, it is an established rule, that in lay hands, modus de non-decimando non-valet. But spiritual persons or corporations, as monasteries, abbots, bishops, and the like, were always capable of having their lands totally discharged of tithes, by various ways: as By real composition : By the pope's bull of exemption : By unity of possession; as when the rectory of a parish, and lands in the same parish, both belonged to a religious house, those lands were discharged of tithes by this unity of possession : By prescription; having never been liable to tithes, by being always in spiritual hands : By virtue of their order; as the knights templars, cistercians, and others, whose lands were privileged by the pope with a discharge of tithes. Though, upon the dissolution of abbeys by Henry VIII, most of these exemptions from tithes would have fallen with them, and the lands become tithable again; had they not been supported and upheld by the statute 31 Hen. VIII. c. 13. which enacts, that all persons who should come to the possession of the lands of any abbey then dissolved, should hold them free and discharged of tithes, in as large and ample a manner as the abbeys themselves formerly held them. And from this original have sprung all the lands, which, being in lay hands, do at present claim to be tithe-free: for, if a man can shew his lands to have been such abbey lands, and also immemorially discharged of tithes by any of the means before-mentioned, this is now a good prescription de non-decimando. But he must shew both these requisites; for abbey lands, without a special ground of discharge, are not discharged of course; neither will any prescription de non-decimando avail in total discharge of tithes, unless it relates to such abbeylands. Finland All members of either the Evangelical Lutheran Church of Finland and the Finnish Orthodox Church (the two state churches of Finland) pay an income-based church tax of between 1% and 2%, depending on