その他令和7年7月4日
不動産所得からの収入（第6条）
号外p.25 - p.26
号外p.25-p.26
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ARTICLE6
INCOME FROM IMMOVABLE PROPERTY
1.Income derived by a resident of a Contracting State from immovable property
(including income from agriculture or forestry) situated in the other Contracting State
may be taxed in that other Contracting State.
2. The term "immovable property" shall have the meaning which it has under the
law of the Contracting State in which the property in question is situated. The term shall
in any case include property accessory to immovable property, livestock and equipment
used in agriculture and forestry, rights to which the provisions of general law respecting
landed property apply, usufruct of immovable property and rights to variable or fixed
payments as consideration for the working of, or the right to work, mineral deposits.
sources and other natural resources; ships and aircraft shall not be regarded as immovable
property.
3. The provisions of paragraph 1 shall apply to income derived from the direct use.
letting, or use in any other form of immovable property.
十
4. The provisions of paragraphs1 and3 shall also apply the income from
immovable property of an enterprise.
ARTICLE 7
BUSINESS PROFITS
1. Profits of an enterprise of a Contracting State shall be taxable only in that
Contracting State unless the enterprise carries on business in the other Contracting State
through a permanent establishment situated therein. If the enterprise carries on business
as aforesaid, the profits that are attributable to the permanent establishment in accordance
with the provisions of paragraph 2 may be taxed in that other Contracting State
1.0. For the purposes of this Article and Article 21, the profits that are attributable0.0
each Contracting State to the permanent establishment referred to in paragraph 1 are the
profits it might be expected to make, in particular in its dealings with other parts of the
enterprise, if it were a separate and independent enterprise engaged in the same or similar
activities under the same or similar conditions, taking into account the functions
performed, assets used and risks assumed by the enterprise through the permanent
establishment and through the other parts of the enterprise.
3. Where, in accordance with paragraph 2, a Contracting State adjusts the profits that
are attributable to a permanent establishment of an enterprise of one of the Contracting
States and taxes accordingly profits of the enterprise that have been charged to tax in the
other Contracting State, that other Contracting State shall, to the extent necessary to
eliminate double taxation on these profits, make an appropriate adjustment to the amount
of the tax charged therein on those profits. In determining such adjustment, the
competent authorities of the Contracting States shall if necessary consult each other.
ナ
.. Where profits include items of income which are dealt with separately in other
Articles of this Convention, then the provisions of those Articles shall not be affected by
the provisions of this Article.
ARTICLE8
INTERNATIONAL SHIPPING AND AIR TRANSPORT
1. Profits of an enterprise of a Contracting State from the operation of ships or
aircraft in international traffic shall be taxable only in that Contracting State
For the purposes of this Article, profits of an enterprise from the operation of ships
or aircraft in international traffic shall include
(a) profits from the rental on a bareboat basis of ships or aircraft; and
(b) profits from the use, maintenance or rental of containers (including trailers
and related equipment for the transport of containers) used for the
transport of goods or merchandise.
where such rental or such use, maintenance or rental, as the case may be, is incidental to
the operation of ships or aircraft in international traffic carried on by that enterprise.
3. Notwithstanding the provisions of Article 2, an enterprise of a Contracting State
shall be exempt in respect of its carrying on the operation of ships or aircraft in
international traffic from, in the case of an enterprise of Ukraine, the enterprise tax of
Japan and, in the case of an enterprise of Japan, any tax similar to the enterprise tax of
Japan which is imposed after the date of signature of this Convention in Ukraine
p.25 / 2
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