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Key Points of Tax Convention with Uruguay

Japanese

[Provisional translation]

1. Taxation on Business Profits

Where an enterprise of one of the two countries has in the other country a permanent establishment (such as a branch, including the furnishing of services by an enterprise through personnel over a certain period of time) through which the enterprise carries on business, only the profits attributable to the permanent establishment may be taxed in that other country. The profits attributable to a permanent establishment will be calculated by comprehensively recognizing internal dealings between its head office and branches and by strictly applying the arm’s length principle.

2. Taxation on Investment Income

Taxation on investment income (dividends, interest and royalties) in the source country will be subjected to the maximum rates or exempted as follows:

investment income (dividends, interest and royalties)
Dividends5% (holding for 183 days at least 10% of: 
       where paid by a company of Japan, voting power;
       where paid by a company of Uruguay, capital)
10% (others)
InterestExempted (received by the Governments, paid and received between financial institutions etc.)
10% (others)
Royalties10%

3. Prevention of Abuse of the Convention

In order to prevent abuse of benefits under this Convention, any benefit under this Convention will not be granted if it is reasonable to conclude that obtaining such a benefit was one of the principal purposes of any transaction, or if the income is attributable to a permanent establishment in a third country and does not satisfy specified conditions.

4. Mutual Agreement Procedure and Arbitration Proceedings

Taxation not in accordance with the provisions of this Convention may be resolved by mutual agreement between the tax authorities of the two countries. In addition, where such taxation has not been resolved through the consultation between the tax authorities of the two countries within two years, the unresolved issue will be resolved pursuant to a decision of an arbitration panel composed of third parties.

5. Exchange of Information and Assistance in Collection of Tax Claims

In order to effectively prevent international tax evasion and tax avoidance, the exchange of information concerning tax matters and the mutual assistance in the collection of tax claims between the two countries are introduced.