Press Releases
Signing of the Tax Agreement between Japan and the Kyrgyz Republic
December 19, 2025
On December 19, “Agreement between Japan and the Kyrgyz Republic for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” (Tax Agreement) was signed in Tokyo by Mr. MOTEGI Toshimitsu, Minister for Foreign Affairs of Japan, and H.E. Mr. Bakyt SYDYKOV, Minister of Economy and Commerce of the Kyrgyz Republic.
- This Agreement wholly amends the existing Convention (Convention between the Government of Japan and the Government of the Union of Soviet Socialist Republics for the Avoidance of Double Taxation with respect to Taxes on Income), which entered into force in 1986, by revising the taxation on business profits and investment income, introducing measures for prevention of abuse of this Agreement and reinforcing the exchange of information concerning tax matters. It is expected that, while eliminating double taxation and preventing international tax evasion and tax avoidance, this Agreement promotes further mutual investments and economic exchanges between the two countries.
- The following are the key points of this Agreement.
- Taxation on Business Profits
Where an enterprise of one of the two countries has in the other country a permanent establishment (such as a branch) through which the enterprise carries on business, only the profits attributable to the permanent establishment may be taxed in that other country. - Taxation on Investment Income
Taxation on investment income (dividends, interest and royalties) in the source country will be subjected to the maximum rates or exempted as follows:
(a) Existing Convention
Dividends : 15%
Interest : Exempted (received by the Governments, etc.)
10% (others)
Royalties : Exempted (copyright)
10% (others)
(b) New Agreement
Dividends : 5% (holding for 6 months at least 10% of: where paid by a company of Japan, voting power; where paid by a company of the Kyrgyz Republic, capital)
10% (others)
Interest : Exempted (received by the Governments, etc.)
8% (others))
Royalties : 8% - Mutual Agreement Procedure
Taxation not in accordance with the provisions of the Agreement may be resolved by mutual agreement between the tax authorities of the two countries. - Exchange of Information
In order to effectively prevent international tax evasion and tax avoidance, the scope of taxes and cases subject to the exchange of information concerning tax matters between the two countries is expanded. - Prevention of Abuse of the Agreement
In order to prevent abuse of benefits under the Agreement, any benefit under the Agreement will not be granted if it is reasonable to conclude that obtaining such a benefit was one of the principal purposes of any transaction.
- Taxation on Business Profits
- After the completion of the domestic procedures in each of the two countries (in Japan, approval by the Diet is necessary), each of the two countries shall send through diplomatic channels to the other country the notification confirming the completion of its internal procedures. This Agreement will enter into force on the thirtieth day after the date of receipt of the latter notification and will have effect:
- in Japan:
(a) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after the first day of January of the calendar year next following the year in which this Agreement enters into force;
(b) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after the first day of January of the calendar year next following the year in which this Agreement enters into force; - in the Kyrgyz Republic:
(a) with respect to taxes withheld at source, for amounts paid or credited on or after the first day of January of the calendar year next following the year in which this Agreement enters into force;
(b) with respect to other taxes, for taxes for taxable years beginning on or after the first day of January of the calendar year next following the year in which this Agreement enters into force.
- in Japan:
(Reference1)
The Agreement will not affect the application of the current Tax Convention (Convention between the Government of Japan and the Government of the Union of Soviet Socialist Republics for the Avoidance of Double Taxation with respect to Taxes on Income) applicable between Japan and some of the former Soviet Union countries other than the Kyrgyz Republic.
(Reference2) Attachment
“Agreement between Japan and the Kyrgyz Republic for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” ( Japanese (PDF) 
/ English (PDF) )