Entry into Force of the Protocol Amending the Convention between Japan and Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
1. On September 12, 2014, the Government of Japan sent to the Government of Sweden the notification, informing the completion of its internal procedures necessary for the entry in to force of “the Protocol Amending the Convention between the Government of Japan and the Government of Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income” (signed on December 5, 2013). The Government of Sweden has already sent its notification for the same effect to the Government of Japan.
2. Therefore, the Protocol will enter into force on October 12, 2014, and will have effect:
(1) in respect of taxes withheld at source, for amounts paid or credited on or after January 1, 2015; and
(2) in respect of other taxes on income, as regards income for taxable years beginning on or after January 1, 2015.
3. The provisions concerning the arbitration proceedings will have effect from October 12, 2014, with respect to:
(1) cases that are under consideration by the tax authorities of both countries on October 12, 2014. However, unresolved issues of that cases will not be submitted to arbitration earlier than three years after October 12, 2017.
(2) cases that come under consideration by the tax authorities of both countries after October 12, 2014.
4. The provisions concerning the information exchange and the mutual assistance in tax collection will have effect from October 12, 2014, without regard to the taxable year to which the matter or revenue claim relates.
5. This Protocol amends part of the current Tax Convention, which entered into force in 1983 (partial amendment entered into force in 1999), and it is expected that this Protocol will further strengthen the economic relations and human exchanges between Japan and Sweden, and contribute to the prevention of fiscal evasion.