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Japan Publishes Synthesized Text of Tax Treaties with Israel, New Zealand, Poland, Slovak Republic, Sweden, and the UK as Impacted by the BEPS MLI

Japan's Ministry of Finance has published the synthesized texts of the tax treaties with Israel, New Zealand, Poland, the Slovak Republic, Sweden, and the UK as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The Synthesized Texts contain the consolidated text of the provisions of a tax treaty (as amended by amending protocols) and the provisions of the MLI applicable to that tax treaty. They are to be used solely for the purpose of facilitating the understanding of the application of the MLI to a tax treaty and do not constitute a source of law.

The synthesized texts and the effective dates of the MLI provisions as provided by Japan's Ministry of Finance are as follows:

1993 Tax Treaty with Israel

The provisions of the MLI shall have effect in each Contracting State with respect to the treaty:

  • In Japan:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019; and
    • with respect to all other taxes levied by Japan, for taxes levied with respect to taxable periods beginning on or after 1 July 2019; and
  • In Israel:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 January 2019; and
    • with respect to all other taxes levied by Israel, for taxes levied with respect to taxable periods beginning on or after 1 January 2020.

2012 Tax Treaty with New Zealand

The provisions of the MLI shall have effect in each Contracting State with respect to the treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019; and
  • with respect to all other taxes levied by that Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 July 2019.

1980 Tax Treaty with Poland

The provisions of the MLI shall have effect in each Contracting State with respect to the treaty:

  • with respect to taxes withheld at source on amounts paid or credited to nonresidents, where the event giving rise to such taxes occurs on or after 1 January 2019; and
  • with respect to all other taxes levied by that Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 July 2019.

1977 Tax Treaty with the Slovak Republic (former Czechoslovakia)

The provisions of the MLI shall have effect in each Contracting State with respect to the treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019; and
  • with respect to all other taxes levied by that Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 July 2019.

1983 Tax Treaty with Sweden

The provisions of the MLI shall have effect in each Contracting State with respect to the treaty:

  • In Japan:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next calendar year that begins on or after 30 days after the date of receipt by the Depositary of the notification by Sweden that it has completed its internal procedures for the entry into effect of the provisions of the MLI with respect to the Convention; and
    • with respect to all other taxes levied by Japan, for taxes levied with respect to taxable periods beginning on or after the expiration of a period of six calendar months from 30 days after the date of receipt by the Depositary of the notification by Sweden that it has completed its internal procedures for the entry into effect of the provisions of the MLI with respect to the Convention; and
  • In Sweden:
    • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next calendar year that begins on or after 30 days after the date of receipt by the Depositary of the notification by Sweden that it has completed its internal procedures for the entry into effect of the provisions of the MLI with respect to the Convention; and
    • with respect to all other taxes levied by Sweden, for taxes levied with respect to taxable periods beginning on or after 1 January of the next year beginning on or after the expiration of a period of six calendar months from 30 days after the date of receipt by the Depositary of the notification by Sweden that it has completed its internal procedures for the entry into effect of the provisions of the MLI with respect to the Convention.

2006 Tax Treaty with the UK

The provisions of the MLI shall have effect in each Contracting State with respect to the treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2019; and
  • with respect to all other taxes levied by that Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 July 2019.

Click the following link for the Ministry of Finance's webpage on the BEPS MLI for more information.

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