Japan: New income tax treaty with Germany | KPMG | GLOBAL
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Japan: New income tax treaty with Germany, entry into force

Japan: New income tax treaty with Germany

Japan’s Ministry of Finance on 30 September 2016 announced that mutual notifications necessary for the entry into force of the income tax treaty between Japan and Germany, as signed in December 2015, were completed on 28 September 2016. Therefore, the new Japan-Germany income tax treaty will enter into force on 28 October 2016 (30 days after the date of receipt of the latter notification).


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The treaty’s provisions will be effective according to the following schedules: 


Japan Taxes levied on the basis of a tax year Taxes for any tax years beginning on or after 1 January 2017
Taxes not levied on the basis of a tax year Taxes levied on or after 1 January 2017
Germany Taxes withheld at source Amounts paid on or after 1 January 2017
Other taxes Taxes levied for periods beginning on or after 1 January 2017


The new treaty will supersede the current agreement that was concluded in 1967 (and then partly amended in 1980 and in 1984) by revising the business profits provision; expanding the reduction in taxes at source for investment income; and introducing anti-abuse provisions, provisions for arbitration proceedings in mutual agreement procedures, and for assistance in the collection of taxes, among other items.


Read a September 2016 report [PDF 114 KB] prepared by the KPMG member firm in Japan

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