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Protocol Amending Tax Convention with the United Kingdom will Enter into Force

November 13, 2014

Ministry of Finance

Protocol Amending Tax Convention with the United Kingdom will Enter into Force

[Provisional translation]

1.  On November 12 (Wed.), an exchange of diplomatic notes for the entry into force of the 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 (signed on December 17, 2013) took place in London.

2.  Therefore, the Protocol will enter into force on December 12, 2014 (the thirtieth day after the date of exchange of diplomatic notes) and will be applicable:

(a)  in Japan
(i)  with respect to taxes withheld at source, for amounts taxable on or after January 1, 2015; and

(ii)  with respect to taxes on income which are not withheld at source, as regards income for any taxable year beginning on or after January 1, 2015; and

(b)  in the United Kingdom:
(i)  with respect to taxes withheld at source, to income derived on or after January 1, 2015;

(ii)  subject to clause (i) of subparagraph (b) of this paragraph, with respect to income tax and capital gains tax, for any year of assessment beginning on or after April 6, 2015; and

(iii)  with respect to corporation tax, for any financial year beginning on or after April 1, 2015.

3.  Notwithstanding paragraph 2, the provisions concerning the taxation on business profits amended by the Protocol will be applicable with respect to profits for any taxable year or chargeable period beginning on or after a date to be agreed between both governments through another exchange of diplomatic notes. Until the amended provisions concerning the taxation on business profits are applicable, the original provisions concerning the taxation on business profits continue to apply.

4.  Notwithstanding paragraph 2, provisions concerning the mutual agreement procedure, the exchange of information and the assistance in collection of taxes will have effect from December 12, 2014, without regard to the taxable year or chargeable period to which the matter relates. For the purposes of the provisions concerning the arbitration process in the course of the mutual agreement procedure, no case may be submitted to arbitration earlier than December 12, 2016.

[References]

  • ”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” (JapaneseEnglish (159KB/192KB)PDF)
  • ”Exchanged Notes concerning the Convention to be Amended by the 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” (JapaneseEnglish (66KB / 20KB)PDF)
  • See below for the outline of the Protocol.

    Protocol Amending Tax Convention with United Kingdom was Signed (December 18, 2013)