On July 5, 2017 the Japanese Ministry of Finance issued a press release announcing that on that same date the exchange of diplomatic notes between the Government of Japan and the Government of the Republic of Latvia for entry into force of the Convention between Japan and the Republic of Latvia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance, which was signed on January 18, 2017, (Hereafter: the DTA) took place in Tokyo.
Based on Article 30, Paragraph 1 of the DTA (“ENTRY INTO FORCE”) the fact that the exchange of diplomatic notes between the Government of Japan and the Government of the Republic of Latvia for entry into force of the DTA took place on July 5, 2017 means that the DTA entered into force on that same that.
Based on Article 30, Paragraph 2 of the DTA the fact that the DTA entered into force on July 5, 2017 means that the DTA shall have effect:
(a) in the case of Japan:
(i) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after January 1, 2018; and
(ii) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1, 2018; and
(b) in the case of Latvia:
(i) with respect to taxes withheld at source, on income derived on or after January 1, 2018; and
(ii) with respect to other taxes, for taxes chargeable for any taxable year beginning on or after January 1, 2018.
Article 30, Paragraph 3 of the DTA arranges that notwithstanding the provisions of Article 30, Paragraph 2, the provisions of Articles 26 (“EXCHANGE OF INFORMATION”) and 27(“ASSISTANCE IN THE COLLECTION OF TAXES”) shall have effect from the date of entry into force of this Convention without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.
For a further analysis of the DTA we refer to our article from January 20, 2017, which also contains links to the text of the DTA.
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