December 26, 2024
Ministry of Finance
New Tax Convention with Armenia was Signed
1. Today, the Government of Japan and the Government of the Republic of Armenia signed the “Convention between Japan and the Republic of Armenia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” in Yerevan.
2. This Convention wholly amends the existing Convention, which entered into force in 1986, by revising the taxation on business profits and investment income, introducing measures for prevention of abuse of this Convention, arbitration proceedings in mutual agreement procedures and assistance in the collection of tax claims, and reinforcing the exchange of information concerning tax matters. It is expected that, while eliminating double taxation and preventing international tax evasion and tax avoidance, this Convention promotes further mutual investments and economic exchanges between the two countries.
* This Convention will not affect the existing Convention applicable between Japan and the countries other than the Republic of Armenia.
【Reference 1】 Next Steps
(a) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after 1 January in the calendar year next following that in which this Convention enters into force;
(b) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after 1 January in the calendar year next following that in which this Convention enters into force.
(a) with respect to cases presented pursuant to the provisions concerning the mutual agreement procedure on or after the date to be agreed between the Governments of the Contracting States through an exchange of diplomatic notes;
(b) with respect to cases presented pursuant to the provisions concerning the mutual agreement procedure before the date to be agreed between the Governments of the Contracting States through an exchange of diplomatic notes. In this case, no unresolved issues of such case shall be submitted to arbitration before two years have elapsed from that date.
【Reference 2】 Texts and Key Points of the Convention

