On August 26, 2016 the Japanese Ministry of finance issued issued a press release announcing that on August 25, 2016 Japan and Panama signed a Tax Information Exchange Agreement (TIEA). Although signed, the TIEA has not yet entered into force. For the TIEA to enter into force, the respective ratification procedures have to have been finalized in both countries.

Below we will discuss a selection of regulations included in the TIEA of which we think they might interest our readers.

Article 3 of the TIEA (“Taxes Covered”) arranges that the TIEA shall apply to taxes of every kind and description imposed on behalf of a Contracting Party or of its political subdivisions or local authorities.

Article 5 of the TIEA contains regulations regarding the exchange of information upon request.

Article 6 of the TIEA contains regulations regarding the automatic exchange of information which read as follows: “With respect to categories of cases and in accordance with procedures which the competent authorities of the Contracting Parties shall determine by mutual agreement, they shall automatically exchange information for the purposes referred to in Article 1.”

Article 10 of the TIEA contains regulations regarding a Mutual Agreement Procedure.

The TIEA does not seem to contain regulations regarding possibilities for conducting tax examinations abroad.

Click here to be forwarded to the text of the TIEA as available in the English language on the website of the Japanese Ministry of Finance, which will open in a new window.

Click here to be forwarded to the text of the TIEA as available in the Japanese language on the website of the Japanese Ministry of Finance, which will open in a new window.

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