May 28, 2026
Ministry of Finance
New Tax Convention with the Philippines was Signed
1. Today, the Government of Japan and the Government of the Republic of the Philippines signed the “Convention between Japan and the Republic of the Philippines for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” in Tokyo.
2. This Convention wholly amends the existing Convention, which entered into force in 1980 and was partly amended in 2008, 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.
【Reference 1】 Next Steps
After the approval in accordance with the domestic procedures of the two countries (in Japan, approval by the Diet is necessary), this Convention will enter into force on the thirtieth day after the date of exchange of diplomatic notes indicating such approval and will have effect:
(i) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after the first day of January in the calendar year next following that in which this Convention enters into force;
(ii) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after the first day of January in the calendar year next following that in which this Convention enters into force;
(b) in the Republic of the Philippines:
(i) with respect to taxes withheld at source, for taxable amount derived on or after the first day of January in the calendar year next following that in which the Convention enters into force;
(ii) with respect to other taxes, for income and other taxable objects arising on or after the first day of January in the calendar year next following that in which the Convention enters into force.
The provisions concerning the arbitration proceedings have effect:
(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.
The provisions concerning the exchange of information and the assistance in the collection of taxes will have effect from the following dates without regard to the date on which the taxes are levied or the taxable year to which the taxes relate:
(b) with respect to the provisions of the assistance in the collection of taxes, the date to be agreed between the Governments of the Contracting States through an exchange of diplomatic notes.
【Reference 2】 Texts and Key Points of the Convention
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