(September 16, 2014)
The Japanese Ministry of Finance has issued a press release stating that on September 12, 2014 mutual notifications necessary for the entry into force of the “Protocol Amending the Convention betweenJapan andSweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income” (signed on December 5, 2013) were completed.
The extensive Protocol contains several amendments to the existing Japanese – Swedish tax treaty.
Article XX of the Protocol contains regulations regarding the entry into force and the dates as of which the amendments made by the Protocol will have effect.
Based on paragraph 2 of Article XX of the Protocol, the Protocol will enter into force on October 12, 2014 (the thirtieth day after the date of receipt of the latter notification), and will have effect:
(1) in respect of taxes withheld at source, for amounts paid or credited on or after January 1, 2015; and
(2) in respect of other taxes on income, as regards income for taxable years beginning on or after January 1, 2015.
Paragraph 3 of Article XX of the Protocol arranges that notwithstanding paragraph 2, provisions concerning the arbitration proceeding will have effect from October 12, 2014, with respect to:
(1) cases that are under consideration by the tax authorities of the two countries on October 12, 2014. For such cases, no unresolved issues arising therefrom will be submitted to arbitration earlier than October 12, 2017.
(2) cases that come under consideration by the tax authorities of the two countries after October 12, 2014.
Pragraph 4 of Article XX of the Protocol arranges that notwithstanding paragraph 2, provisions concerning exchange of information and assistance in collection of taxes will have effect from October 12, 2014, without regard to the taxable year to which the matter or revenue claim relates.
Click here to be forwarded to the text of the ”Protocol Amending the Convention between Japan and Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income” as it is published on the website of the Japanese Government, which will open in a new window. (Click here for the Japanese version);
Click here to be forwarded to the ”Exchanged Notes concerning the Convention to be Amended by the Protocol Amending the Convention between Japan and Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”, as published on the website of the Japanese Ministry of Finance. (Click here for the Japanese version)
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