March 21, 2013
Ministry of Finance
Agreement in Principle on the Protocol Amending the Tax Convention with the United Kingdom
The Government of Japan and the Government of the United Kingdom of Great Britain and Northern Ireland have agreed in principle on the draft Protocol amending the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains which entered into force in 2006.
The draft Protocol amends part of the current Convention in order to reduce taxation on investment income (dividends and interest) in the source country, introduce an arbitration system to the mutual agreement procedure between the tax authorities, and introduce a system to lend assistance to each other in the collection of revenue claims of the other country, with a view to promoting investment and economic exchanges between the two countries and preventing international tax evasion and tax avoidance.
The Protocol will be signed after the necessary domestic procedures have been completed by the two Governments. Thereafter, the Protocol will enter into force after the completion of the approval process on both sides (in the case of Japan, approval by the Diet will be necessary).
[Reference] History of Japan-U.K. Tax Conventions
(1) Original Convention: Entered into force in 1963
(2) The first totally amended Convention: Entered into force in 1970
(3) The second totally amended Convention (the current Convention): Entered into force in 2006