Entry into Force of the Protocol Amending the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains

November 13, 2014
Japanese

  1. 1. On November 12, the Government of Japan and the Government of the United Kingdom of Great Britain and Northern Ireland exchanged diplomatic notes in London for entry into force of “the Protocol Amending the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains” (signed on December 17, 2013).

    2. Therefore, the Protocol will enter into force on December 12, 2014 and will be applicable:

    (a) in Japan:

    (i) with respect to taxes withheld at source, for amounts taxable on or after January 1, 2015; and

    (ii) with respect to taxes on income which are not withheld at source, as regards income for any taxable year beginning on or after January 1, 2015; and

    (b) in the United Kingdom:

    (i) with respect to taxes withheld at source, to income derived on or after January 1, 2015;

    (ii) subject to clause (i) of subparagraph (b) of this paragraph, with respect to income tax and capital gains tax, for any year of assessment beginning on or after April 6, 2015; and

    (iii) with respect to corporation tax, for any financial year beginning on or after April 1, 2015.

    3. The amended provisions concerning the taxation on business profits will be applicable with respect to profits for any taxable year or chargeable period beginning on or after a date to be agreed between both governments through another exchange of diplomatic notes. Until the amended provisions are applicable, the original provisions concerning the taxation on business profits will continue to apply.

    4. The provisions concerning the mutual agreement procedure, the exchange of information and the assistance in collection of taxes will have effect from December 12, 2014, without regard to the taxable year or chargeable period to which the matter relates. For the purpose of the provisions concerning the arbitration process in the course of the mutual agreement procedure, no case may be submitted to arbitration earlier than December 12, 2016.

    5. This Protocol amends a part of the current Tax Convention, which entered into force in 2006, and it is expected that this Protocol will further strengthen the economic relations and people to people exchanges between Japan and the United Kingdom of Great Britain and Northern Ireland, contributing to the prevention of fiscal evasion.