The protocol to the 2006 income and capital tax treaty between Japan and the U.K. will enter into force 12 December 2014. The protocol, signed 17 December 2013, is the first to amend the treaty. Key changes are summarized as follows. Business Profits The article on business profits is amended to include the provision that business income attributable to a PE will be calculated based on the arm’s length principle as if the PE were a separate and independent enterprise from its head office. Dividends The article on dividends is changed to provide withholding tax exemption if the beneficial owner...