On November 1, 2023 the Government and Japan and the Government of the Hellenic Republic signed a Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (Hereafter: the DTA). This DTA is the first DTA to be concluded between Japan and the Hellenic Republic.
It should be noted that the although the DTA has been signed it does not yet enter into force. For the DTA to enter into force shall be approved in accordance with the legal procedures of each of the Contracting States and shall enter into force on the thirtieth day after the date of exchange of diplomatic notes indicating such approval.
After the aforementioned approval has been given the DTA shall have effect:
(a) in the Hellenic Republic:
(i) with respect to taxes withheld at source, for amounts paid or credited on or after January 1 of the calendar year next following that in which the Convention enters into force;
(ii) with respect to other taxes, for taxes levied for periods beginning on or after January 1 of the calendar year next following that in which the Convention enters into force;
(b) in Japan:
(i) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after January 1 of the calendar year next following that in which the Convention enters into force;
(ii) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1 of the calendar year next following that in which the Convention enters into force.
Notwithstanding the aforementioned, the provisions of Articles 25 (EXCHANGE OF INFORMATION) and 26 (ASSISTANCE IN THE COLLECTION OF TAXES) shall have effect from the date of entry into force of this Convention without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.
The text of the DTA can be found here in the English language and here in the Japanese language.
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