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The Convention to Implement Measures to Prevent BEPS will Have Effect with respect to the Tax Treaty with Hong Kong

March 3, 2023

Ministry of Finance

The Convention to Implement Measures to Prevent BEPS will Have Effect
with respect to the Tax Treaty with Hong Kong

[Provisional translation]

1. According to the publication as of February 21, 2023 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 submitted the notification that it had completed its internal procedures for the entry into effect of the provisions of this Convention with respect to the tax treaty between Japan and Hong Kong.

2. The provisions of this Convention, accordingly, shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Hong Kong:
(a) in Japan:
(i)   with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after January 1, 2024; and
(ii)   with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after September 23, 2023; and
(b) in Hong Kong:
(i)   with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after March 23, 2023; and
(ii)   with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable periods beginning on or after September 23, 2023.

3.  For the details of the application of this Convention to the tax treaty between Japan and Hong Kong, see the webpage 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)

  [ Hong Kong ]
   └Summary
   └Synthesised Text (Japanese(PDF:338KB)English(PDF:263KB))

Tax Treaties Covered by the Convention to Implement Measures to Prevent BEPS will be Increased [ China and Hong Kong ] (June 3, 2022)