On 16 July 2014, the U.K. ratified the pending protocol to the 2006 income and capital tax treaty with Japan. 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. This is in line with the OECD model. Dividends The article on dividends is changed to provide withholding tax exemption if the beneficial owner holds at least 10% of the paying...