Japan: New tax treaty with Germany (agreement in principle)

Japan: New tax treaty with Germany

The Japanese Ministry of Finance on 16 July 2015 announced that the governments of Japan and Germany reached an “agreement in principle” for a new income tax treaty. The new treaty would replace the existing agreement signed in 1966, and subsequently amended in 1979 and in 1983.


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According to a press release, the new tax treaty would provide for:

  • Reduced rates of tax withheld at source on investment income (dividends, interest, and royalties)
  • An update of the treaty provision concerning the taxation of business profits
  • Introduction of an arbitration system for the mutual agreement procedure and an article concerning assistance in the collection of taxes

It is expected that the treaty will be signed after Japan and Germany each complete certain domestic procedures, and at that time, details of the amendment will be clarified.

Read a July 2015 report [PDF 132 KB] prepared by the KPMG member firm in Japan: New Japan-Germany Tax Agreement-Agreement in Principle

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