日本国政府とウクライナ政府との間の所得税に関する二重課税の排除及び脱税又は逃税の防止のための条約
令和7年7月4日|p.21
左の本文を選ぶと、右側の官報原文画像で該当箇所を照合できます。
(右条約の英文)
CONVENTION BETWEEN
THE GOVERNMENT OF JAPAN AND THE GOVERNMENT OF UKRAINF
FOR THE ELIMINATION OF DOUBLE TAXATION
WITH RESPECT TO TAXES ON INCOME
AND THE PREVENTION OF TAX EVASION AND AVOIDANCE
The Government of Japan and the Government of Ukraine,
Desiring to further develop their economic relationship and to enhance their co-
operation in tax matters,
Intending to conclude a Convention for the elimination of double taxation with
respect to taxes on income without creating opportunifies for non-taxation or reduced
taxation through tax evasion or avoidance (including through treaty-shopping
arrangements aimed at obtaining reliefs provided in this Convention for the indirect
benefit of residents of third States),
Have agreed as follows:
ARTICLE 1
PERSONS COVERED
1. This Convention shall apply to persons who are residents of one or both of the
Contracting States.
2. For the purposes of this Convention, income derived by or through an entity or
arrangement that is treated as wholly or partly fiscally transparent under the tax law of
either Contracting State shall be considered to be income of a resident of a Contracting
State but only to the extent that the income is treated, for purposes of taxation by that
Contracting State, as the income of a resident of that Contracting State.
3. This Convention shall not affect the taxation, by a Contracting State, of its
residents except with respect to the benefits granted under paragraph 3 of Article 7,
paragraph 2 of Article 9 and Articles 18, 19, 21,22,23 and 26.
ARTICLE2
TAXES COVERED
1. This Convention shall apply to taxes on income imposed on behalf of a
Contracting State or of its political subdivisions or local authorities, irrespective of the
manner in which they are levied
2. There shall be regarded as taxes on income all taxes imposed on total income or
on elements of income, including taxes on gains from the alienation of any property, taxes
on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital
appreciation.
3. The existing taxes to which this Convention shall apply are:
(a) in Japan:
(i) the income tax;
(ii) the corporation tax;
() the special income tax for reconstruction;
(iv) the local coration tax; and
(v) the local inhabitaxes
(hereinafter referred to as "Japanese tax");
(b) in Ukraine:
(i) the individual income tax; and
(ii) tax of enterprofits of enterprises
(hereinafter referred to as "Ukrainian tax").