その他令和6年11月8日
租税条約（利息及び使用料に関する条文）
号外p.19 - p.28
号外p.19-p.28
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日本国とギリシャ共和国との間の所得に対する租税に関する条約の署名及び効力発生
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(b) the interest is beneficially owned by a resident of that other Contracting State with respect to debt-claims guaranteed, insured or indirectly financed by that other Contracting State, a political subdivision or local authority thereof, the central bank of that other Contracting State or any institution wholly owned by that other Contracting State or a political subdivision or local authority thereof.
4. The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures as well as other income that is subjected to the same taxation treatment as income from money lent by the laws of the Contracting State in which the income arises. Income dealt with in Article 10 shall not be regarded as interest for the purposes of this Article.
5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.
6. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that Contracting State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the Contracting State in which the permanent establishment is situated.
7. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.
ARTICLE 12
ROYALTIES
1. Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State.
2. However, royalties arising in a Contracting State may also be taxed in that Contracting State according to the laws of that Contracting State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the gross amount of the royalties.
3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, or any patent, trade mark, design or model, plan, or secret formula or process, for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall apply.
ARTICLE 13
CAPITAL GAINS
1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State.
2. Gains from the alienation of any property, other than immovable property referred to in Article 6, forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other Contracting State.
3. (a) Gains that an enterprise of a Contracting State derives from the alienation of ships, or of any property, other than immovable property, referred to in Article 6, pertaining to the operation of such ships, shall be taxable only in that Contracting State unless the ships are registered in, or documented by, the other Contracting State. If the ships are registered or documented as aforesaid, the gains that are derived from the alienation of the ships, or of any property, other than immovable property, referred to in Article 6, pertaining to the operation of the ships, may be taxed in that other Contracting State.
(b) Gains that an enterprise of a Contracting State that operates aircraft in international traffic derives from the alienation of such aircraft, or of any property, other than immovable property, referred to in Article 6, pertaining to the operation of such aircraft, shall be taxable only in that Contracting State.
4. Gains derived by a resident of a Contracting State from the alienation of shares of a company or comparable interests, such as interests in a partnership or trust, may be taxed in the other Contracting State if, at any time during the 365 days preceding the alienation, these shares or comparable interests derived at least 50 per cent of their value directly or indirectly from immovable property, as defined in Article 6, situated in that other Contracting State, unless such shares or comparable interests are traded on a recognised stock exchange and the resident and persons related to that resident own in the aggregate 5 per cent or less of the class of such shares or comparable interests.
5. Gains from the alienation of any property, other than that referred to in paragraphs 1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator is a resident.
ARTICLE 14
INCOME FROM EMPLOYMENT
1. Subject to the provisions of Articles 15, 17 and 18,
salaries, wages and other similar remuneration derived by a
resident of a Contracting State in respect of an employment
shall be taxable only in that Contracting State unless the
employment is exercised in the other Contracting State. If
the employment is so exercised, such remuneration as is
derived therefrom may be taxed in that other Contracting
State.
2. Notwithstanding the provisions of Paragraph 1,
remuneration derived by a resident of a Contracting State
in respect of an employment exercised in the other
Contracting State shall be taxable only in the first-
mentioned Contracting State if:
(a) the recipient is present in the other Contracting
State for a period or periods not exceeding in
the aggregate 183 days in any twelve month period
commencing or ending in the taxable year
concerned, and
(b) the remuneration is paid by, or on behalf of, an
employer who is not a resident of the other
Contracting State, and
(c) the remuneration is not borne by a permanent
establishment which the employer has in the other
Contracting State.
3. Notwithstanding the preceding provisions of this
Article, remuneration derived by a resident of a
Contracting State in respect of an employment, as a member
of the regular complement of a ship or aircraft, that is
exercised aboard a ship or aircraft operated in
international traffic, other than aboard a ship or aircraft
operated solely within the other Contracting State, shall
be taxable only in the first-mentioned Contracting State.
ARTICLE 15
DIRECTORS' FEES
Directors' fees and other similar payments derived by
a resident of a Contracting State in his capacity as a
member of the board of directors, or of a similar organ, of
a company which is a resident of the other Contracting
State may be taxed in that other Contracting State.
ARTICLE 16
ENTERTAINERS AND SPORTSPERSONS
1. Notwithstanding the provisions of Article 14, income
derived by a resident of a Contracting State as an
entertainer, such as a theatre, motion picture, radio or
television artiste, or a musician, or as a sportsperson,
from that resident's personal activities as such exercised
in the other Contracting State, may be taxed in that other
Contracting State.
2. Where income in respect of personal activities
exercised by an entertainer or a sportsperson acting as
such accrues not to the entertainer or sportsperson but to
another person, that income may, notwithstanding the
provisions of Article 14, be taxed in the Contracting State
in which the activities of the entertainer or sportsperson
are exercised.
ARTICLE 17
PENSIONS
Subject to the provisions of paragraph 2 of Article
18, pensions and other similar remuneration beneficially
owned by a resident of a Contracting State shall be taxable
only in that Contracting State.
ARTICLE 18
GOVERNMENT SERVICE
1.
(a) Salaries, wages and other similar remuneration
paid by a Contracting State or a political
subdivision or local authority thereof to an
individual in respect of services rendered to
that Contracting State or political subdivision
or local authority shall be taxable only in that
Contracting State.
(b) However, such salaries, wages and other similar
remuneration shall be taxable only in the other
Contracting State if the services are rendered in
that other Contracting State and the individual
is a resident of that other Contracting State
who:
(i) is a national of that other Contracting
State; or
(ii) did not become a resident of that other
Contracting State solely for the purpose of
rendering the services.
2.
(a)
Notwithstanding the provisions of paragraph 1,
pensions and other similar remuneration paid by,
or out of funds which are created by or to which
contributions are made by, a Contracting State or
a political subdivision or local authority thereof
to an individual in respect of services rendered
to that Contracting State or political
subdivision or local authority shall be taxable
only in that Contracting State.
(b)
However, such pensions and other similar
remuneration shall be taxable only in the other
Contracting State if the individual is a resident
of, and a national of, that other Contracting
State.
3.
The provisions of Articles 14, 15, 16 and 17 shall
apply to salaries, wages, pensions, and other similar
remuneration in respect of services rendered in connection
with a business carried on by a Contracting State or a
political subdivision or local authority thereof.
ARTICLE 19
STUDENTS
Payments which a student or business apprentice who is
or was immediately before visiting a Contracting State a
resident of the other Contracting State and who is present
in the first-mentioned Contracting State solely for the
purpose of his education or training receives for the
purpose of his maintenance, education or training shall not
be taxed in that Contracting State, provided that such
payments arise from sources outside that Contracting State.
In the case of a business apprentice, the exemption
provided by this Article shall apply only for a period not
exceeding one year from the date on which he first begins
his training in that Contracting state.
ARTICLE 20
SILENT PARTNERSHIP
Notwithstanding any other provisions of this
Convention, any income derived by a resident of a
Contracting State in respect of contributions made pursuant
to a silent partnership (in the case of Japan, Tokumei
Kumiai) contract or another similar contract may be taxed
in the other Contracting State according to the laws of
that other Contracting State, provided that such income
arises in that other Contracting State and is deductible in
computing the taxable income of the payer in that other
Contracting State.
ARTICLE 21
OTHER INCOME
1.
Items of income beneficially owned by a resident of a
Contracting State, wherever arising, not dealt with in the
foregoing Articles of this Convention shall be taxable only
in that Contracting State.
2.
The provisions of paragraph 1 shall not apply to
income, other than income from immovable property as
defined in paragraph 2 of Article 6, if the beneficial
owner of such income, being a resident of a Contracting
State, carries on business in the other Contracting State
through a permanent establishment situated therein and the
right or property in respect of which the income is paid is
effectively connected with such permanent establishment.
In such case the provisions of Article 7 shall apply.
3.
Where, by reason of a special relationship between the
payer and the beneficial owner or between both of them and
some other person, the amount of the income referred to in
paragraph 1 exceeds the amount which would have been agreed
upon by the payer and the beneficial owner in the absence
of such relationship, the provisions of this Article shall
apply only to the last-mentioned amount. In such case, the
excess part of the income shall remain taxable according to
the laws of each Contracting State, due regard being had to
the other provisions of this Convention.
ARTICLE 22
ELIMINATION OF DOUBLE TAXATION
1.
In the Hellenic Republic, double taxation shall be
eliminated as follows:
(a)
Where a resident of the Hellenic Republic derives
income which, in accordance with the provisions
of this Convention, may be taxed in Japan, the
Hellenic Republic shall allow as a deduction from
the Hellenic tax on the income of that resident,
an amount equal to the Japanese tax paid in
Japan. Such deduction shall not, however, exceed
that part of the Hellenic tax, as computed before
the deduction is given, which is attributable to
the income which may be taxed in Japan.
ARTICLE 23
NON-DISCRIMINATION
1. Nationals of a Contracting State shall not be
subjected in the other Contracting State to any taxation or
any requirement connected therewith, which is other or more
burdensome than the taxation and connected requirements to
which nationals of that other Contracting State in the same
circumstances, in particular with respect to residence,
are or may be subjected. The provisions of this paragraph
shall, notwithstanding the provisions of Article 1, also
apply to persons who are not residents of one or both of
the Contracting States.
2. The taxation on a permanent establishment which an
enterprise of a Contracting State has in the other
Contracting State shall not be less favourably levied in
that other Contracting State than the taxation levied on
enterprises of that other Contracting State carrying on the
same activities. The provisions of this paragraph shall
not be construed as obliging a Contracting State to grant
to residents of the other Contracting State any personal
allowances, reliefs and reductions for taxation purposes on
account of civil status or family responsibilities which it
grants to its own residents.
3. Except where the provisions of paragraph 1 of Article
9, paragraph 7 of Article 11, paragraph 6 of Article 12 or
paragraph 3 of Article 21 apply, interest, royalties and
other disbursements paid by an enterprise of a Contracting
State to a resident of the other Contracting State shall,
for the purpose of determining the taxable profits of such
enterprise, be deductible under the same conditions as if
they had been paid to a resident of the first-mentioned
Contracting State.
4. Enterprises of a Contracting State, the capital of
which is wholly or partly owned or controlled, directly or
indirectly, by one or more residents of the other
Contracting State, shall not be subjected in the first-
mentioned Contracting State to any taxation or any
requirement connected therewith which is other or more
burdensome than the taxation and connected requirements to
which other similar enterprises of the first-mentioned
Contracting State are or may be subjected.
5. The provisions of this Article shall, notwithstanding
the provisions of Article 2, apply to taxes of every kind
and description imposed on behalf of a Contracting State or
of its political subdivisions or local authorities.
ARTICLE 24
MUTUAL AGREEMENT PROCEDURE
1. Where a person considers that the actions of one or
both of the Contracting States result or will result for
him in taxation not in accordance with the provisions of
this Convention, he may, irrespective of the remedies
provided by the domestic law of those Contracting States,
present his case to the competent authority of either
Contracting State. The case must be presented within three
years from the first notification of the action resulting
in taxation not in accordance with the provisions of the
Convention.
2. The competent authority shall endeavour, if the
objection appears to it to be justified and if it is not
itself able to arrive at a satisfactory solution, to
resolve the case by mutual agreement with the competent
authority of the other Contracting State, with a view to
the avoidance of taxation which is not in accordance with
the provisions of this Convention. Any agreement reached
shall be implemented notwithstanding any time limits in the
domestic law of the Contracting States.
ARTICLE 25
EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that Contracting State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
Notwithstanding the foregoing, information received by a Contracting State may be used for other purposes when such information may be used for such other purposes under the laws of both Contracting States and the competent authority of the Contracting State supplying the information authorises such use.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
(b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
(c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public).
3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
4. The competent authorities of the Contracting States may communicate with each other directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs of this Article.
5. Where,
(a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and
(b) the competent authorities are unable to reach an agreement to resolve that case pursuant to paragraph 2 within three years from the date when all the information required by the competent authorities in order to address the case has been provided to both competent authorities,
any unresolved issues arising from the case shall be submitted to arbitration if the person so requests in writing. These unresolved issues shall not, however, be submitted to arbitration if a decision on these issues has already been rendered by a court or administrative tribunal of either Contracting State. Unless a person directly affected by the case does not accept the mutual agreement that implements the arbitration decision, that decision shall be binding on both Contracting States and shall be implemented notwithstanding any time limits in the domestic laws of these Contracting States. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this paragraph.
ARTICLE 26
ASSISTANCE IN THE COLLECTION OF TAXES
1. The Contracting States shall lend assistance to each other in the collection of revenue claims. This assistance is not restricted by Articles 1 and 2. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Article.
2. The term "revenue claim" as used in this Article means an amount owed in respect of the following taxes, insofar as the taxation thereunder is not contrary to this Convention or any other instrument to which the Contracting States are parties, as well as interest, administrative penalties and costs of collection or conservancy related to such amount:
(a) in the Hellenic Republic:
(i) the taxes referred to in subparagraph (a) of paragraph 3 of Article 2;
(ii) the value added tax;
(iii) the inheritance tax;
(iv) the gift tax;
(v) the tax on transfer of immovable property;
(vi) the tax on real estate;
(vii) the tax on luxury goods;
(viii) the special consumption taxes on goods and services; and
(ix) the road tax on motor vehicles;
(b) in Japan:
(i) the taxes referred to in clauses (i) to (iv) of subparagraph (b) of paragraph 3 of Article 2;
(ii) the special corporation tax for reconstruction;
(iii) the consumption tax;
(iv) the local consumption tax;
(v) the inheritance tax; and
(vi) the gift tax;
(c) any other tax as may be agreed upon from time to time between the Governments of the Contracting States through an exchange of diplomatic notes; and
(d) any identical or substantially similar taxes that are imposed after the date of signature of the Convention in addition to, or in place of, the taxes referred to in subparagraph (a), (b) or (c).
3. When a revenue claim of a Contracting State is enforceable under the laws of that Contracting State and is owed by a person who, at that time, cannot, under the laws of that Contracting State, prevent its collection, that revenue claim shall, at the request of the competent authority of that Contracting State, be accepted for purposes of collection by the competent authority of the other Contracting State. That revenue claim shall be collected by that other Contracting State in accordance with the provisions of its laws applicable to the enforcement and collection of its own taxes as if the revenue claim were a revenue claim of that other Contracting State that met the conditions allowing that other Contracting State to make a request under this paragraph.
4. When a revenue claim of a Contracting State is a claim in respect of which that Contracting State may, under its law, take measures of conservancy with a view to ensure its collection, that revenue claim shall, at the request of the competent authority of that Contracting State, be accepted for purposes of taking measures of conservancy by the competent authority of the other Contracting State. That other Contracting State shall take measures of conservancy in respect of that revenue claim in accordance with the provisions of its laws as if the revenue claim were a revenue claim of that other Contracting State even if, at the time when such measures are applied, the revenue claim is not enforceable in the first-mentioned Contracting State or is owed by a person who has a right to prevent its collection.
5. Notwithstanding the provisions of paragraphs 3 and 4, a revenue claim accepted by the competent authority of a Contracting State for purposes of paragraph 3 or 4 shall not, in that Contracting State, be subject to the time limits or accorded any priority applicable to a revenue claim under the laws of that Contracting State by reason of its nature as such. In addition, a revenue claim accepted by the competent authority of a Contracting State for the purposes of paragraph 3 or 4 shall not, in that Contracting State, have any priority applicable to that revenue claim under the laws of the other Contracting State.
6. Acts carried out by a Contracting State in the collection of a revenue claim accepted by the competent authority of that Contracting State for purposes of paragraph 3 or 4 which if they were carried out by the other Contracting State would have the effect of suspending or interrupting the time limits applicable to the revenue claim in accordance with the laws of that other Contracting State shall have such effect under the laws of that other Contracting State. The competent authority of the first-mentioned Contracting State shall inform the competent authority of the other Contracting State of the acts which the first-mentioned Contracting State has carried out in the collection of the revenue claim.
7. Proceedings with respect to the existence, validity or the amount of a revenue claim of a Contracting State shall not be brought before the courts or administrative bodies of the other Contracting State.
8. Where, at any time after a request has been made by the competent authority of a Contracting State under paragraph 3 or 4 and before the other Contracting State has collected and remitted the relevant revenue claim to the first-mentioned Contracting State, the relevant revenue claim ceases to be
(a) in the case of a request under paragraph 3, a revenue claim of the first-mentioned Contracting State that is enforceable under the laws of that Contracting State and is owed by a person who, at that time, cannot, under the laws of that Contracting State, prevent its collection, or
(b) in the case of a request under paragraph 4, a revenue claim of the first-mentioned Contracting State in respect of which that Contracting State may, under its laws, take measures of conservancy with a view to ensure its collection
the competent authority of the first-mentioned Contracting State shall promptly notify the competent authority of the other Contracting State of that fact and, at the option of the competent authority of that other Contracting State, the competent authority of the first-mentioned Contracting State shall either suspend or withdraw its request.
9. In no case shall the provisions of this Article be construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
(b) to carry out measures which would be contrary to public policy (ordre public);
(c) to provide assistance if the other Contracting State has not pursued all reasonable measures of collection or conservancy, as the case may be, available under its laws or administrative practice;
(d) to provide assistance in those cases where the administrative burden for that Contracting State is clearly disproportionate to the benefit to be derived by the other Contracting State.
ARTICLE 27
MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS
Nothing in this Convention shall affect the fiscal
privileges of members of diplomatic missions or consular
posts under the general rules of international law or under
the provisions of special agreements.
ARTICLE 28
ENTITLEMENT TO BENEFITS
1. Where under any provisions of this Convention income
derived by a resident of a Contracting State is relieved or
exempted from tax in the other Contracting State and, under
the law of the first-mentioned Contracting State, that
resident is subjected to tax by reference to the amount
thereof which is remitted to or received in that
Contracting State and not by reference to the full amount
thereof, then the relief or exemption provided under the
Convention in the other Contracting State shall apply only
to so much of such income as is taxed in the first-
mentioned Contracting State.
2. (a) Where
(i) an enterprise of a Contracting State derives
income from the other Contracting State and
the first-mentioned Contracting State treats
such income as attributable to a permanent
establishment of the enterprise situated in
a third jurisdiction, and
(ii) the profits attributable to that permanent
establishment are exempt from tax in the
first-mentioned Contracting State,
the benefits under this Convention shall not
apply to any item of income on which the tax in
the third jurisdiction is less than 60 per cent
of the tax that would be imposed in the first-
mentioned Contracting State on that item of
income if that permanent establishment were
situated in the first-mentioned Contracting
State. In such a case, any income to which the
provisions of this paragraph apply shall remain
taxable according to the domestic law of the
other Contracting State, notwithstanding any
other provisions of the Convention.
(b) The provisions of subparagraph (a) shall not
apply if the income derived from the other
Contracting State described in that subparagraph
emanates from, or is incidental to, the active
conduct of a business carried on through the
permanent establishment (other than the business
of making, managing or simply holding investments
for the enterprise's own account, unless these
activities are banking, insurance or securities
activities carried on by a bank, insurance
enterprise or registered securities dealer,
respectively).
(c) If the benefits under the Convention are denied
pursuant to the provisions of subparagraph (a)
with respect to an item of income derived by a
resident of a Contracting State, the competent
authority of the other Contracting State may,
nevertheless, grant these benefits with respect
to that item of income if, in response to a
request by such resident, such competent
authority determines that granting such benefits
is justified in light of the reasons such
resident did not satisfy the requirements of
subparagraphs (a) and (b) (such as the existence
of losses). The competent authority of the
Contracting State to which a request has been
made under the preceding sentence by a resident
of the other Contracting State shall consult with
the competent authority of that other Contracting
State before either granting or denying the
request.
3. Notwithstanding the other provisions of this
Convention, a benefit under the Convention shall not be
granted in respect of an item of income if it is reasonable
to conclude, having regard to all relevant facts and
circumstances, that obtaining that benefit was one of the
principal purposes of any arrangement or transaction that
resulted directly or indirectly in that benefit, unless it
is established that granting that benefit in these
circumstances would be in accordance with the object and
purpose of the relevant provisions of the Convention.
ARTICLE 29
ENTRY INTO FORCE
1. This Convention shall be approved in accordance with
the legal procedures of each of the Contracting States and
shall enter into force on the thirtieth day after the date
of exchange of diplomatic notes indicating such approval.
ARTICLE 30
TERMINATION
This Convention shall remain in force until terminated
by a Contracting State. Either Contracting State may
terminate the Convention by giving notice of termination
through diplomatic channels to the other Contracting State
at least six months before the end of any calendar year
beginning after expiry of five years from the date of entry
into force of the Convention. In such event, the
Convention shall cease to have effect:
(a) in the Hellenic Republic:
(i) with respect to taxes withheld at source,
for amounts paid or credited on or after 1
January of the calendar year next following
that in which the notice is given;
(ii) with respect to other taxes, for taxes
levied for periods beginning on or after 1
January of the calendar year next following
that in which the notice is given;
(b) in Japan:
(i) with respect to taxes levied on the basis of
a taxable year, for taxes for any taxable
years beginning on or after 1 January of the
calendar year next following that in which
the notice is given;
(ii) with respect to taxes levied not on the
basis of a taxable year, for taxes levied on
or after 1 January of the calendar year next
following that in which the notice is given.
IN WITNESS WHEREOF the undersigned, being duly
authorised thereto by their respective Governments, have
signed this Convention.
DONE in duplicate at Athens this first day of
November, 2023, in the English language.
For Japan:
中山泰則
Ambassador Extraordinary
and Plenipotentiary of
Japan to the Hellenic Republic
For the Hellenic Republic:
K I Hads
Minister of National Economy
and Finance
p.19 / 10
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