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U.S. IRS Publishes Competent Authority Arrangement with Japan on Arbitration

|Treaty Development|United States-Japan
United States-Japan

The U.S. IRS has published the competent authority arrangement with Japan regarding arbitration. The arrangement, signed 3 February 2021, provides for the implementation of the arbitration process provided for in paragraphs 5, 6, and 7 of Article 25 (Mutual Agreement Procedure) of the 2003 income tax treaty between the two countries as amended by the 2013 Protocol. Subject to certain exception…

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