Agreement on the substance on the new Tax Agreement between the Government of Japan and the Government of the Federal Republic of Germany
July 16, 2015
1. The representatives of the Government of Japan and the Government of the Federal Republic of Germany have agreed in principle on a new Agreement that replaces the Agreement between Japan and the Federal Republic of Germany for the Avoidance of Double Taxation with respect to Taxes on Income and to certain other Taxes signed in 1966 as amended in 1979 and 1983.
2. The new Agreement wholly amends the contents of the current Agreement. The new Agreement reduces taxes withheld at source on investment income (dividends, interest and royalties) to further promote the investment exchanges between the two countries, updates the article concerning taxation on business profits, and introduces the arbitration proceeding to the mutual agreement procedure to ensure the settlement of disputes with respect to the Agreement. The new Agreement also expands the cooperation between the tax authorities of the two countries by introducing an Article concerning assistance in the collection of taxes.
3. The new Agreement will be signed after the necessary internal procedures have been completed by each of the two Governments. Thereafter, the new Agreement will enter into force after the completion of the approval process on both sides (in the case of Japan, approval by the Diet is necessary).