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Press Release

Japanese

August 30, 2019

Ministry of Finance

Protocol Amending Tax Convention with the United States Entered into Force

[Provisional translation]
1. Today, the exchange of instruments of ratification between the Government of Japan and the Government of the United States of America for the entry into force of the Protocol Amending the Convention between the Government of Japan and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (signed on January 24, 2013) took place in Tokyo.

2. This Protocol, accordingly, entered into force today (the date of exchange of instruments of ratification) and will have effect:
  (a) in respect of taxes withheld at source, for amounts paid or credited on or after 1 November, 2019;
  (b) in respect of other taxes, for taxable years beginning on or after 1 January, 2020.

The provisions concerning arbitration will have effect from today with respect to:
  (a) Cases that are under consideration by the tax authorities as of today.
  (b) Cases that come under consideration after today.

The provisions concerning exchange of information and assistance in the collection of taxes will have effect from today, without regard to the taxable year to which the matter or revenue claim relates.

【Reference】Texts and Outline of the Protocol
・“Protocol Amending the Convention between the Government of Japan and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”(Japanese(PDF:118KB)English(PDF:80KB)
・“Exchanged Notes concerning the Convention to be Amended by the Protocol Amending the Convention between the Government of Japan and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income” (Japanese(PDF:111KB)English(PDF:47KB)
・Outline of the Protocol.
Protocol Amending the Tax Convention eith the United States was Signed(January 25,2013)

Contact

Ministry of Finance : Tel 03(3581)4111
International Tax Policy Division, Tax Bureau (ext. 5081)