September 27, 2018
Ministry of Finance
Convention to Implement Measures to Prevent BEPS will Enter into Force
[Provisional translation]
1. On September 26, Japan deposited the instrument of acceptance of the “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” (Convention to Implement Measures to Prevent BEPS) to the Secretary-General of the Organisation for Economic Co-operation and Development (OECD) acting as the Depositary of this Convention.
2. Accordingly, this Convention will enter into force for Japan on January 1, 2019 (on the first day of the month following the expiration of a period of three calendar months beginning on the date of the deposit of the instrument of acceptance).
3. 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 treaties between Japan and the following jurisdictions will satisfy those requirements on January 1, 2019.
- Israel
- New Zealand
- Poland
- Sweden
- United Kingdom
This Convention will also apply to a tax treaty between Japan and a jurisdiction other than the above-mentioned jurisdictions if those requirements are subsequently satisfied for that tax treaty.
4. 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) ）
◆List of Reservations and Notifications of Signatories and Parties to the Convention to Implement Measures to Prevent BEPS [link to the website of the OECD]
◆Convention to Implement Measures to Prevent BEPS (MLI)
-List of Reservations and Notifications of Japan （Japanese(PDF:256KB)・English(PDF:236KB)）
-Application of the MLI to Japan's Tax Treaties
2. Accordingly, this Convention will enter into force for Japan on January 1, 2019 (on the first day of the month following the expiration of a period of three calendar months beginning on the date of the deposit of the instrument of acceptance).
3. 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 treaties between Japan and the following jurisdictions will satisfy those requirements on January 1, 2019.
- Israel
- New Zealand
- Poland
- Sweden
- United Kingdom
This Convention will also apply to a tax treaty between Japan and a jurisdiction other than the above-mentioned jurisdictions if those requirements are subsequently satisfied for that tax treaty.
4. 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) ）◆List of Reservations and Notifications of Signatories and Parties to the Convention to Implement Measures to Prevent BEPS [link to the website of the OECD]
◆Convention to Implement Measures to Prevent BEPS (MLI)
-List of Reservations and Notifications of Japan （Japanese(PDF:256KB)
・English(PDF:236KB)）-Application of the MLI to Japan's Tax Treaties