TKs – treatment under different tax treaties

With such a large population it can be difficult to find fishing spots

The attached table lists up the treatment under Japan’s tax treaties of Japan source income arising from cross border investment in tokumei kumiai contracts.

Note that this table should not be relied upon alone and the application of the detailed terms of the treaty to a particular transaction should always be considered. Changes may also have been made to the treaties or other relevant law since this post. The table in the excel sheet linked above is also reproduced below.

Treatment of income from tokumei kumiai under Japan’s tax treaties
Ref Country Treatment Article
  OECD Model Treaty Taxation in country of resident 21
  Japan model treaty As OECD Model Treaty  
1 Ireland Taxation in country of resident 23
2 Argentina Taxation in country of resident 19
3 USA Taxation in country of resident 21
4 Armenia Taxation in country of resident 19
5 United Kingdom Taxed under the law of the country of source 20
6 Israel Also taxable in the country of source 22
7 Italy Taxation in country of resident 22
8 India Also taxable in the country of source 22
9 Indonesia Taxation in country of resident 22
10 Ukraine Taxation in country of resident 19
11 Uzbekistan Taxation in country of resident 19
12 Egypt Not addressed in treaty  
13 Australia Not addressed in treaty  
14 Austria Not addressed in treaty  
15 Netherlands Taxation in country of resident 23
16 Canada Also taxable in the country of source 20
17 Korea Taxation in country of resident 22
18 Kirgiz Taxation in country of resident 19
19 Georgia Taxation in country of resident 19
20 Zambia Taxation in country of resident 21
21 Singapore Also taxable in the country of source 21
22 Switzerland Taxation in country of resident 22
23 Sweden Also taxable in the country of source 21
24 Spain Taxation in country of resident 22
25 Sri Lanka Not addressed in treaty  
26 Slovakia Taxation in country of resident 22
27 Thailand Also taxable in the country of source 20
28 Tajikistan Taxation in country of resident 19
29 Czech Republic Taxation in country of resident 22
30 People’s Republic of China Also taxable in the country of source 22
31 Denmark Taxation in country of resident 22
32 Germany Taxable under domestic law 10(8)
33 Turkmenistan Taxation in country of resident 19
34 Turkey Also taxable in the country of source 21
35 New Zealand Not addressed in treaty  
36 Norway Also taxable in the country of source 22
37 Pakistan Not addressed in treaty  
38 Hungary Taxation in country of resident 22
39 Bangladesh Also taxable in the country of source 22
40 Fiji Not addressed in treaty  
41 Philippines Taxation in country of resident 22
42 Finland Taxation in country of resident 22
43 Brazil Also taxable in the country of source 21
44 France Taxation in country of resident 22
45 Bulgaria Also taxable in the country of source 22
46 Vietnam Taxation in country of resident 21
47 Belorussia Taxation in country of resident 19
48 Belgium Taxation in country of resident 22
49 Poland Taxation in country of resident 22
50 Malaysia Also taxable in the country of source 21
51 South Africa Also taxable in the country of source 20
52 Mexico Also taxable in the country of source 21
53 Moldavia Taxation in country of resident 19
54 Luxembourg Also taxable in the country of source 22
55 Romania Not addressed in treaty  
56 Russia Taxation in country of resident 19



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