Tax Treaties Covered by the Convention to Implement Measures to Prevent BEPS will be Increased [ China and Hong Kong ]

June ３, 2022

Ministry of Finance

Tax Treaties Covered by the Convention to Implement Measures to Prevent BEPS will be Increased
[ China and Hong Kong ]

1. According to the publication as of May 25, 2022 by the Secretary-General of the Organisation for Economic Co-operation and Development (OECD) acting as the Depositary of the "Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting" (Convention to Implement Measures to Prevent BEPS), China, being a party to one of the tax treaties of Japan to which it had chosen to apply this Convention, newly deposited its instrument of approval of this Convention. China also submitted reservations and notifications in respect of tax treaties entered into by Hong Kong.

2. This Convention applies to an existing tax treaty where both parties to that tax treaty have chosen to apply this Convention to it and where this Convention has entered into force for those parties. The tax treaties between Japan and China and between Japan and Hong Kong will satisfy those requirements on September 1, 2022.

3. The provisions of this Convention applicable to an existing tax treaty and the timing of entry into effect of this Convention for it are determined depending on the choices of each of the parties to that tax treaty. For the details of the application of this Convention to the tax treaties of Japan, see the webpages below.