On June 24, 2021 the Japanese Ministry of Finance issued a press release announcing that on June 23, the exchange of diplomatic notes between the Government of Japan and the Government of the Oriental Republic of Uruguay for the entry into force of “Convention between Japan and the Oriental Republic of Uruguay for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance” (signed on September 13, 2019) (hereafter: the DTA) took place in Montevideo.

 

Based on Article 29, Paragraph 1 of the DTA (“ENTRY INTO FORCE”) the fact that the exchange of diplomatic notes took place on June 23, 2021 means that the DTA will enter into force on July 23, 2021.

 

Based on Article 29, Paragraph 2 of the DTA the fact that the DTA will enter into force on July 23, 2021 means that the provisions of the DTA shall have effect:

(a)  with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after January 1, 2022; and

(b)  with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1, 2022.

 

With respect to the exchange of information (Article 25 of the DTA) and the assistance in the collection of taxes (Article 26 of the DTA) Article 29, Paragraph 3 of the DTA arranges that these provisions shall have effect from July 23, 2021 without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.

 

The English text of the DTA can be found here.

 

The Japanese text of the DTA can be found here.

 

 

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