Signing of the Protocol Amending the Convention between the Government of Japan and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

January 25, 2013
Japanese

The Protocol Amending the Convention between the Government of Japan and the Government of the United States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income was signed on January 25, 2013 (January 24, 2013 EST), at Washington D.C. between the Government of Japan and the Government of the United States of America.
This Protocol amends part of the current Convention, which entered into force in 2004. This Protocol expands the subject of exemption of taxes withheld at source on dividends and interest to promote mutual investments, as well as introduces the arbitration system to promote settlement of tax related disputes with respect to the Convention. This Protocol also reinforces mutual cooperation between tax authorities of the both States such as by expanding the subject of mutual assistance for tax collection.

[Reference] Future procedures
This Protocol will enter into force on the date of the exchange of the instruments of ratification after the completion of their respective domestic procedures, and shall in principle have effect:

(1) in respect of taxes withheld at source, for amounts paid or credited on or after the first day of the third month next following the date on which the Protocol enters into force;

(2) in respect of other taxes, for taxable years beginning on or after the first day of January next following the date on which the Protocol enters into force.

(* The foregoing is a provisional translation. The date indicated above denotes the date of issue of the original press release in Japanese.)

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Protocol Amending the Convention between the Government of Japan and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income[PDF]
Exchange of Notes[PDF]

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