(November 25, 2014)

On November 25, 2014 the Japanese Ministry of Finance issued a press release announcing that on November 24, 2014 an exchange of diplomatic notes for the entry into force of the Convention between Japan and the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (signed on May 2, 2013) took place in Abu Dhabi.

According to the press release this means that the Convention will enter into force on December 24, 2014 and will be applicable:

 

(1)    with respect to taxes withheld at source, for amounts taxable on or after January 1, 2015;

 

(2)    with respect to taxes on income which are not withheld at source, as regards income for any taxable/fiscal year beginning on or after January 1, 2015; and

 

(3)    with respect to other taxes, as regards taxes for any taxable/fiscal year beginning on or after January 1, 2015.

 

Furthermore the press release states that with the entry into force of the Convention, taxes on income from the international transportation business will be exempted in the source country under the Convention. Therefore on the same date (November 24, 2014) in Abu Dhabi, the two governments signed the Exchanged Notes regarding the termination of the agreement made by the Exchanged Notes between the Government of Japan and the Government of the United Arab Emirates concerning Mutual Tax Exemption for Income from the International Transportation Business dated June 27, 2004. Accordingly, the agreement will terminate and cease to have effect with respect to income or taxes to which the Convention applies in accordance with paragraph 2. With the termination of the agreement, in Japan, the Cabinet Order of the law concerning mutual tax exemption for income from the international transportation business will be amended, and the law concerning mutual tax exemption for income from the international transportation business will not be applied to income derived by a resident of the United Arab Emirates from the international transportation business.

The text of the Convention between Japan and the United Arab Emirates for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income is available in English and Japanese on the website of the Japanese Ministry of Finance.

The text of the Exchanged Notes regarding the Termination of the Agreement between the Government of Japan and the Government of the United Arab Emirates concerning Mutual Tax Exemption for Income from the International Transportation Business is available in Japanese on the website of the Japanese Ministry of Finance.

 

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