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Protocol to Tax Treaty between Japan and the U.S. has Entered into Force

03 September 2019

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Treaty Development

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Japan-United States

The amending protocol to the 2003 income tax treaty between Japan and the U.S. entered into force on 30 August 2019. The protocol, signed 24 January 2013, provides for the following main changes: Paragraph 4 of Article 4 (Residence) is replaced, including that where a person other than an individual is a resident of both Contracting States, such person shall not be considered a resident of either Contracting State for the purposes of its claiming any benefits provided by this Convention (the provision regarding the competent authorities determining residence through mutual agreement is removed); The conditions for the dividends withholding...