October 21, 2022
Ministry of Finance
Tax Treaties Covered by the Convention to Implement Measures to Prevent BEPS will be Increased
[ South Africa ]
[Provisional translation]
1. According to the publication as of Octorber 6, 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), South Africa, 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 ratification, acceptance or approval of this Convention.
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 treaty between Japan and South Africa will satisfy those requirements on January 1, 2023.
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.
◆The text of the Convention to Implement Measures to Prevent BEPS
“Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting”（Japanese(PDF:997KB)
・English(PDF:269KB) ）
“Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting”（Japanese(PDF:997KB)
・English(PDF:269KB) ） ◆Convention to Implement Measures to Prevent BEPS (MLI)
└List of Reservations and Notifications of Japan（Japanese(PDF:491KB)・English(PDF:414KB)）
└Application of the MLI to Japan's Tax Treaties
└List of Reservations and Notifications of Japan（Japanese(PDF:491KB)
・English(PDF:414KB)） └Application of the MLI to Japan's Tax Treaties