Reservations and Declarations for Treaty No.127 - Convention on Mutual Administrative Assistance in Tax Matters

Nature of declaration : Declarations, Denunciations, Derogations
Status as of 25/08/2019

Japan

Declarations deposited at the same time as the instrument of acceptance with the Secretary General of the OECD on 27 June 2013 - Or. Engl. and completed by a letter from the Ministry of Foreign Affairs of Japan, dated 7 July 2014, registered at the Secretariat General of the OECD on 31 July 2014 - Or. Engl.

ANNEX A – Taxes to which the Convention would apply

Pursuant to Article 2, paragraph 2, of the Convention, the Government of Japan declares that the Convention shall apply to those taxes in Article 2, paragraph 1, which fall within:

Sub-paragraph (a)(i)
- the income tax
- the corporation tax
- the special income tax for reconstruction
- the special corporation tax for reconstruction
- the local corporation tax

Sub-paragraph (b)(iii)A
- the inheritance tax
- the gift tax

Sub-paragraph (b)(iii)B
- the land value tax

Sub-paragraph (b)(iii)C
- the consumption tax

Sub-paragraph (b)(iii)D
- the liquor tax
- the tobacco tax
- the special tobacco tax
- the gasoline tax
- the local gasoline tax
- the liquefied petroleum gas tax
- the aviation fuel tax
- the petroleum and coal tax

Sub-paragraph (b)(iii)E
- the motor vehicle tonnage tax

Sub-paragraph (b)(iii)G
- the registration and license tax
- the promotion of power-resources development tax
- the stamp tax
- the local special corporation surtax

[Note of the Secretariat: See declaration of 31 July 2014.]


Period covered: 01/10/2013 -
Articles concerned : 2

Declaration deposited at the same time as the instrument of acceptance with the Secretary General of the OECD on 27 June 2013 - Or. Engl.

Pursuant to Article 4, paragraph 3, of the Convention, the Government of Japan declares that its authorities may inform its resident or national before transmitting information to another Party, in conformity with Article 5 or Article 7 of the Convention.
Period covered: 01/10/2013 -
Articles concerned : 4, 5, 7

Declaration contained in a letter from the Ministry of Foreign Affairs of Japan, dated 7 July 2014, registered at the Secretariat General of the OECD on 31 July 2014 - Or. Engl.

Pursuant to Article 2, paragraph 4, of the Convention as amended, the Government of Japan notifies to the Secretary General of the OECD the adoption of the “local corporation tax” under the Local Corporation Tax Act (Law No. 11 of 2014) of Japan.

“The local corporation tax” is a national tax on income or profit and the tax base is the amount of “the corporation tax” listed in Annex A (sub-paragraph (a)(i)). Therefore, “the local corporation tax” is a substantially similar tax which is imposed in Japan in addition to “the corporation tax” within the meaning of paragraph 4 of Article 2 of the Convention. Since the Local Corporation Tax Act is to be enacted on 1 October 2014, the Convention shall apply to “the local corporation tax” from the same date.
Period covered: 01/10/2014 -
Articles concerned : 2


Source : Treaty Office on http://conventions.coe.int - * Disclaimer.