Japan-Qatar tax treaty to enter into force December 30

Japan’s Ministry of Finance has advised that on November 30 Japan and Qatar exchanged diplomatic for the entry into force of the Japan-Qatar tax treaty, signed on February 20.  As a result, the treaty will enter into force on December 30, the Ministry of Finance said.

Under the agreement, taxation in the source country on dividends is reduced to 5 percent for corporate shareholders that hold at least a 10 percent interest, and is 10 percent in other cases. Taxation in the source country on interest is set at a 10 percent rate, and is set on royalties at a 5 percent rate.

The treaty also exempts from source country taxation international transportation business income.

Further, it provides for exchange of information on tax matters between the tax authorities and a framework for mutual agreement for dispute resolution.

Provisions also address corresponding adjustments in transfer pricing cases and the taxation on income derived in respect of a silent partnership contract. The treaty includes provisions to prevent abuse of the treaty.

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