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

The MLI enters into force for Japan on January 1, 2019, and for Oman on November 1, 2020.
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and July 22, 2020 and by Oman on July 7, 2020, the MLI applies to the tax treaty between Japan and Oman as described below. 

1. Tax treaty covered by the MLI
-“Agreement between the Government of Japan and the Government of the Sultanate of Oman for the Avoidance of
  Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”
   Date of signature: January 9, 2014
   Date of entry into force: September 1, 2014

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 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 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)

3. Entry into effect
(a) The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between
     Japan and Oman: 
   (i) 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, 2021; and
   (ii) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable
       periods beginning on or after May 1, 2021.
(b) Notwithstanding (a), Article 16 (Mutual Agreement Procedure) shall have effect with respect to the tax treaty
     between Japan and Oman for a case presented to the competent authority of a Contracting Jurisdiction on or after
     November 1, 2020, except for cases that were not eligible to be presented as of that date under the tax treaty
     between Japan and Oman prior to its modification by the MLI, without regard to the taxable period to which the
     case relates.