Orbitax

Japan Tax News

OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007

New treaty between Australia and Japan – agreement on general terms

2 September 2007

Non-discrimination and group income elections

2 July 2007

Ministry of Finance releases triangular merger regulations

18 June 2007

Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007

Tokyo Court

28 May 2007

Revised Commentary on Article 7 of OECD Model released

28 May 2007

New case law on Japan-Singapore tax treaty and Japanese CFC provisions

28 May 2007

Treaty between United States and Japan – US court dismisses claims for relief for information exchanged under treaty

24 March 2007

Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007

Tax reform proposals for 2007 – further details (withholding tax, corporate reorganizations, transfer pricing, tax havens, leasing, trusts)

24 March 2007

Treaty between Japan and Australia - negotiations

24 February 2007

Protocol to treaty between Japan and France signed

24 February 2007

Report on Attribution of Profits to PEs released

24 February 2007

Tax reform proposals for 2007

15 January 2007

Protocol to treaty between Japan and Philippines signed

15 January 2007

Treaty between Australia and Japan to be renegotiated

17 December 2006

Treaty between Japan and UK to enter into force

12 November 2006

Treaty between Pakistan and Japan to be signed

14 October 2006

Treaty negotiations between France and Japan finalized

12 September 2006

Treaty between United Arab Emirates and Japan – negotiations

13 August 2006

Protocol to treaty between Japan and Philippines – negotiations

13 August 2006

Treaty between Japan and Philippines – negotiations

14 June 2006

IRS releases list of qualified investment banks under MoU defining investment bank for interest withholding under 2003 Japan-US treaty

14 May 2006

Protocol between Japan and India signed

9 April 2006

Treaty between United Kingdom and Japan signed

16 March 2006

It has been reported that France will begin official negotiations with Japan on 25 January 2006 to revise the France-Japan income tax treaty of 3 March 1995. The main purpose of the revision is to encourage more bilateral investments by lowering the withholding tax rates which are currently fixed at 15% for dividends (5% for qualifying companies), 10% for interest and 10% for royalties

19 February 2006

The Competent Authorities of the United States and Japan have signed a memorandum of understanding (MOU) defining the term "investment bank" for purposes of Art. 11 (Interest) of the 2003 income tax treaty between the two countries. The definition is relevant for determining eligibility for zero-rate withholding for interest payments under Art. 11(3)(c)(i) of the 003 Japan-US Treaty. The MOU was signed on 27 December 2005 and released by the US Internal Revenue Service (IRS) on 28 December 2005.

19 February 2006

The Japanese Ministry of Finance announced on 31 October 2005 that Japan and India have agreed to revise their tax treaty Basically, both countries agreed to partially revise the existing treaty as follows:

6 December 2005

Following a final round of negotiations on 26 May 2005, the United Kingdom and Japan reached an agreement in principle on a new tax treaty. Once in force, the new treaty will replace the United Kingdom-Japan income tax treaty of 10 February 1969 (as amended by the 1980 protocol). Further details of the new treaty are not yet available.

3 August 2005

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