The MLI enters into force for Japan on January 1, 2019, and for Germany on April 1, 2021.
Based on the reservations and notifications submitted by Japan on September 26, 2018 and by Germany on December 18, 2020 and June 1, 2025, the MLI applies to the tax treaty between Japan and Germany as described below.
1. Tax treaty covered by the MLI
2. Provisions of the MLI applicable to the tax treaty
The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Germany:
Based on the reservations and notifications submitted by Japan on September 26, 2018 and by Germany on December 18, 2020 and June 1, 2025, the MLI applies to the tax treaty between Japan and Germany as described below.
1. Tax treaty covered by the MLI
- Agreement between Japan and the Federal Republic of Germany for the Elimination of Double Taxation with respect to Taxes on Income and to certain other Taxes and the Prevention of Tax Evasion and Avoidance
Date of signature: December 17, 2015
Date of entry into force: October 28, 2016
2. Provisions of the MLI applicable to the tax treaty
- 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 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)
3. Entry into effectThe provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Germany:
(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, 2026; 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, 2026.