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Amended Japan-Germany Tax Treaty

Amended Japan-Germany Tax Treaty

On 17 December 2015, the governments of Japan and Germany signed a new tax agreement, which will supersede the current tax agreement concluded in 1967 (partly amended in 1980 and in 1984).

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This newsletter covers the main points of the new tax agreement.

Contents

  1. Preamble
  2. Hybrid Entities (Article 1)
  3. Business Profits (Article 7)
  4. Associated Enterprises (Article 9)
  5. Dividends (Article 10)/Interest (Article 11)/Royalties (Article 12)
  6. Capital Gains (Article 13)
  7. Entitlement to Benefits (Article 21)
  8. Procedural Rules for Taxation at Source (Article 27)
  9. Others
  10. Entry into Force (Article 31)

Japan TAX Newsletter

© 2020 KPMG AZSA LLC, a limited liability audit corporation incorporated under the Japanese Certified Public Accountants Law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. © 2020 KPMG Tax Corporation, a tax corporation incorporated under the Japanese CPTA Law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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