Japan: New income tax treaty signed with Belgium | KPMG | GLOBAL

Japan: New income tax treaty signed with Belgium

Japan: New income tax treaty signed with Belgium

Representatives of the governments of Japan and Belgium on 12 October 2016 signed a new income tax treaty. Once ratified and with its entry into force, the new treaty would replace the existing income tax treaty (1970 and amended in 1990 and 2013). Among the provisions in the new income tax treaty are measures providing for:

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  • A reduction in tax rates on investment income in the source country, including the withholding tax rates on dividends, interest, and royalties
  • An “anti-treaty shopping” provision
  • New clauses or provisions concerning the tax treatment of hybrid entities, corresponding adjustments for associated enterprises, the Japanese “silent partnership” or Tokumei Kumiai, a Mutual Agreement Procedure, and a provision for assistance in the collection of taxes

 

Read an October 2016 report [PDF 248 KB] prepared by the KPMG member firm in Japan: New Japan-Belgium tax treaty signed

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