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Treaty between Japan and United Kingdom (1969) – Japan's NTA uncovers treaty-shopping scheme

|Treaty Development|Japan-United Kingdom
Japan-United Kingdom

Japan's National Tax Agency (NTA) has penalized the Japanese affiliate of a United States-based investment fund, Prospect Asset Management Inc., for failing to withhold taxes on income distributed to foreign investors.

The Japanese affiliate, Prospect Funding Corp., formed a tokumei kumiai (TK) arrangement with foreign investors (including a Bahamas-based company)…

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