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Tax Treaties Covered by the Convention to Implement Measures to Prevent BEPS will be Increased

October 2, 2018

Ministry of Finance

Tax Treaties Covered by the Convention to Implement
Measures to Prevent BEPS will be Increased
[ Australia・Slovakia・France ]

[Provisional translation]
 1. According to the publication as of September 27, 2018 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), the following jurisdictions, being parties to the tax treaties of Japan to which it had chosen to apply this Convention, newly deposited their instruments of ratification, acceptance or approval of this Convention.
    Australia
    Slovakia
    France

 2. 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 above-mentioned jurisdictions will satisfy those requirements on January 1, 2019. 
   
 3. 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