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New Tax Agreement with Germany will Enter into Force

September 30, 2016

Ministry of Finance

New Tax Agreement with Germany will Enter into Force

[Provisional translation]

1.  On September 28 (Wed.), mutual notifications necessary for the entry into force of the “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” (signed on December 17, 2015) were completed.

2.  The Agreement, therefore, will enter into force on October 28, 2016 (the thirtieth day after the date of receipt of the latter notification) and will be applicable:

(a)  in the case of Japan:

(i)  in the case of taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after January 1, 2017; and

(ii)  in the case of taxes not levied on the basis of a taxable year, for taxes levied on or after January 1, 2017; and

(b)  in the case of the Federal Republic of Germany:

(i)  in the case of taxes withheld at source, in respect of amounts paid on or after January 1, 2017; and

(ii)  in the case of other taxes, in respect of taxes levied for periods beginning on or after January 1, 2017.

3.  The provisions concerning the exchange of information shall have effect from October 28, 2016, without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.

[References] 

  • “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” (JapaneseEnglish (329KB/188KB)PDF)
  • See below for the outline of the Agreement.

New Tax Agreement with Germany was Signed (December 17,2015)