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Application of the MLI to the Tax Treaty between Japan and Mexico

 The MLI enters into force for Japan on January 1, 2019, and for Mexico on July 1, 2023.
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and by Mexico on March 15, 2023, the MLI applies to the tax treaty between Japan and Mexico as described below.

1. Tax treaty covered by the MLI
- “Convention between Japan and the United Mexican States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”
       Date of signature: April 9, 1996
       Date of entry into force: November 6, 1996

2. Provisions of the MLI applicable to the tax treaty
    - Article 4(1) (Provisions that provide rules for determining whether a person other than an individual shall be treated as a resident of one of the Contracting Jurisdictions for the purposes of the tax treaty)
    - Article 6(1) (Preamble language describing the intent of the Contracting Jurisdictions that the tax treaty will not create opportunities for non-taxation or reduced taxation)
    - Article 6(3) (Preamble language referring to a desire of the Contracting Jurisdictions to develop their economic relationship and to enhance their co-operation in tax matters)
    - Article 7(1) (Provisions that deny the benefits under the tax treaty where the principal purpose or one of the principal purposes of any arrangement or transaction was to obtain those benefits)
    - Article 9(4) (Provisions for taxation on capital gains from alienation of shares or interests of entities deriving their value principally from immovable property)
    - Article 10(1) to (3) (Provisions that deny the benefits under the tax treaty with respect to a certain income attributable to a permanent establishment situated in a third jurisdiction)
    - Article 12(1) and (2) (Provisions regarding an agent that is deemed to constitute a permeant establishment)
    - Article 13(2) (Provisions regarding an activity that is deemed not to constitute a permanent establishment even if the activity is carried on through a fixed place of business)
    - Article 13(4) (Provisions for combining business activities carried on by closely related persons for the purpose of determining whether a permanent establishment exists)
    - Article 15 (Provisions for the definition of a person closely related to an enterprise)
    - Article 16(1), 1st sentence (Provisions for presentation of a case of taxation not in accordance with the provisions of the tax treaty for a mutual agreement procedure)
    - Article 16(2), 2nd sentence (Provisions that provide that any agreement reached under a mutual agreement procedure shall be implemented)
    - Article 16(3), 2nd sentence (Provisions that allow the competent authorities of the Contracting Jurisdictions to consult together for the elimination of double taxation in cases not provided for in the tax treaty)

3. Entry into effect
  The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Mexico:
(a) with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after January 1, 2024; and
(b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after January 1, 2024.