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

 The MLI enters into force for Japan on January 1, 2019, and for Qatar on April 1, 2020. 
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and February 14, 2020 and by Qatar on December 23, 2019, the MLI applies to the tax treaty between Japan and Qatar as described below.

1. Tax treaty covered by the MLI
  -“Agreement between the Government of Japan and the Government of the State of Qatar for the Avoidance of
    Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”

    Date of signature: February 20, 2015
    Date of entry into force: December 30, 2015

2. Provisions of the MLI applicable to 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 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 Qatar:
      (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 October 1, 2020.
(b) Notwithstanding (a), Article 16 (Mutual Agreement Procedure) shall have effect with respect to the tax treaty
      between Japan and Qatar for a case presented to the competent authority of a Contracting Jurisdiction on or after
      April 1, 2020, except for cases that were not eligible to be presented as of that date under the tax treaty between
      Japan and Qatar prior to its modification by the MLI, without regard to the taxable period to which the case relates.