Share with your friends

Japan: Protocol to income tax treaty with United States, entry into force

Japan: Protocol to income tax treaty with United States

The instruments of ratification for the Protocol amending the income tax treaty between Japan and the United States have been exchanged between the two governments.


Related content

The date of the Protocol’s entry into force is 30 August 2019.

  • Read text of the Protocol and related documents
  • Read today’s release from the U.S. Treasury Department reporting the entry into force of the Protocol to the Japan-United States income tax treaty  

The Protocol amends the existing income tax treaty (2003) and provides for: 

  • Exemption from withholding taxes on interest (subject to certain exceptions)
  • Expansion of the scope of dividends eligible for exemption from withholding tax (allowing 50%-owned companies to qualify, and reducing the required holding period from 12 months to six (6) months)
  • Amendments to the capital gains article for consistency with the Foreign Investment in Real Property Tax Act (FIRPTA)
  • Mandatory binding arbitration of unresolved competent authority cases
  • Provisions to enable the competent authorities to assist each other in the collection of taxes
  • Broad exchange of information between the competent authorities for tax purposes

Read an August 2019 report prepared by the KPMG member firm in Japan

© 2021 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal

Stay up to date with what matters to you

Gain access to personalized content based on your interests by signing up today

Sign up today