Japan and Lithuania signed a first time tax treaty between both countries in Vilnius, Lithuania, on 13 July 2017. The treaty substantially follows the OECD Model Convention. Salient features of the treaty include the following: Residence The residence of dual residents other than natural persons shall be determined by the Competent Authorities based on such factors as place of incorporation, and location of head office or of effective management. Failing such agreement, the person shall not be entitled to relief under the Convention. Permanent Establishment The PE article includes anti-PE avoidance measures as per BEPS Action 7. Withholding Taxes The...