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Application of the MLI to the Tax Treaty between Japan and the United Kingdom

 The MLI enters into force for Japan on January 1, 2019, and for the United Kingdom on October 1, 2018.
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and by the United Kingdom on June 29, 2018, the MLI applies to the tax treaty between Japan and the United Kingdom, as described below.

  1. Tax treaty covered by the MLI
   - “Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the
         Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and
         on Capital Gains”
         Date of signature: February 2, 2006
         Date of entry into force: October 12, 2006
   - “Protocol Amending the Convention between Japan and the United Kingdom of Great Britain and Northern
         Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on
         Income and on Capital Gains”
         Date of signature: December 17, 2013
         Date of entry into force: December 12, 2014

  2. Provisions of the MLI applicable to the tax treaty
  - Article 3(1) (Provisions regarding income derived by or through an entity or arrangement that is treated as
      fiscally transparent)
  - Article 4(1) (Provisions that provide rules for determining whether a person other than an individual shall
      be treated as a resident of one of the Contracting Jurisdictions for the purposes of the tax treaty)
  - Article 6(1) (Preamble language describing the intent of the Contracting Jurisdictions that the tax treaty will
      not create opportunities for non-taxation or reduced taxation)
  - Article 6(3) (Preamble language referring to a desire of the Contracting Jurisdictions to develop their
      economic relationship and to enhance their co-operation in tax matters)
  - Article 7(1) (Provisions that deny the benefits under the tax treaty where the principal purpose or one of the
      principal purposes of any arrangement or transaction was to obtain those benefits)
  - Article 13(4) (Provisions for combining business activities carried on by closely related persons for the
      purpose of determining whether a permanent establishment exists)
  - Article 15 (Provisions for the definition of a person closely related to an enterprise)
  - Article 16(1), 1st sentence (Provisions for presentation of a case of taxation not in accordance with the
      provisions of the tax treaty for a mutual agreement procedure)
  - Article 16(2), 2nd sentence (Provisions that provide that any agreement reached under a mutual agreement
      procedure shall be implemented)
  - Article 17(1) (Provisions regarding corresponding adjustments to taxation in accordance with arm’s length
      principle)

  3. Entry into effect
  (a) The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax
         treaty between Japan and the United Kingdom:
   (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, 2019; 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 July 1, 2019.
  (b) Notwithstanding (a), Article 16 (Mutual Agreement Procedure) shall have effect with respect to the
         tax treaty between Japan and the United Kingdom for a case presented to the competent authority of a
         Contracting Jurisdiction on or after January 1, 2019, except for cases that were not eligible to be
         presented as of that date under the tax treaty between Japan and the United Kingdom prior to its
         modification by the MLI, without regard to the taxable period to which the case relates.