Japan-US Tax Treaty 2013 Protocol: Entry into Force

In an effort to strengthen the bilateral economic relationship and promote cross-border investment, Japan and the US signed a protocol to amend the 2003 income tax treaty between the two countries on 25 January 2013. The 2013 protocol introduces a number of changes to the treaty, such as a general withholding tax exemption for interest, a broader withholding tax exemption for certain dividends, mandatory binding arbitration under the mutual agreement procedure (MAP) and measures to facilitate tax administration.

The protocol entered into force on 30 August 2019, the date Japan and the US exchanged instruments of ratification, and applies to withholding taxes on dividends and interest paid or credited on or after 1 November 2019. For other taxes, the protocol will apply to taxable years beginning on or after 1 January 2020. The mandatory arbitration procedures apply for cases under consideration by the competent authorities on the date the protocol entered into force (30 August 2019) or that come under consideration after that date.

* This Article is based on the relevant Japanese or specific country’s tax law and other authorities in effect on the date of this Article. This Article would not be guaranteed updating if there are any changes in Japanese tax law, any other law, or interpretations by the courts or tax authorities thereof after the date of this Article.

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