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Press Release

Japanese

October 11, 2017

Ministry of Finance

New Tax Convention with Denmark was Signed

[Provisional translation]

1.  Today, the Government of Japan and the Government of the Kingdom of Denmark signed the Convention between Japan and the Kingdom of Denmark for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance in Tokyo.

2.  This Convention wholly amends the existing Convention, which entered into force in 1968, by revising the taxation on business profits, expanding the extent of reduction of taxation on investment income, introducing measures for prevention of abuse of this Convention, arbitration proceedings in mutual agreement procedures and assistance in the collection of tax claims, 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 Convention promotes further mutual investments and economic exchanges between the two countries.


【Reference 1】 Next Steps


After the approval in accordance with the domestic procedures of the two countries (in the case of 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 Convention will enter into force on the thirtieth day after the date of exchange of diplomatic notes indicating such approval and will have effect:

(a)  with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after January 1 in the calendar year next following that in which the Convention enters into force; and


(b)  with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1 in the calendar year next following that in which the Convention enters into force.


(c)  The provisions concerning the exchange of information and assistance in the collection of taxes have effect from the date of entry into force of this Convention without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.


(d)  The provisions concerning the arbitration proceedings have effect:

(ⅰ) with respect to cases presented pursuant to the provisions concerning the mutual agreement procedure on or
after the date to be agreed between the Governments of the Contracting States through an exchange of diplomatic
notes; and

(ⅱ) with respect to cases presented pursuant to the provisions concerning the mutual agreement procedure before
that date. In this case, no unresolved issues of such case shall be submitted to arbitration before two years have
elapsed from that date.

【Reference 2】 Texts and Key Points of the Convention



Contact

Ministry of Finance : Tel 03(3581)4111

 International Tax Policy Division, Tax Bureau (ext. 5004)