その他令和7年7月4日
租税条約（二重課税防止条約）条文抜粋
号外p.28
号外p.28
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4. The provisions of paragraphs 2 and 3 shall not affect the taxation of the company
in respect of the profits out of which the dividends are paid.
5. The term "dividends" as used in this Article means income from shares or other
rights, not being debt-claims, participating in profits, as well as income from other rights
which is subjected to the same taxation treatment as income from shares by the laws of
the Contracting State of which the company making the distribution is a resident.
6. The provisions of paragraphs 1,2 and 3 shall not apply if the beneficial owner of
the dividends, being a resident of a Contracting State, carries on business in the other
Contracting State of which the company paying the dividends is a resident through a
permanent establishment situated therein and the holding in respect of which the
dividends are paid is effectively connected with such permanent establishment. In such
case the provisions of Article 7 shall apply.
1/
7. Where a company which5.0%%0000000000000000000)))0000))))))))111).)...tt)e..0tttttteeet0a resident of a Contracting State derives profits or
income from the other Contracting State, that other Contracting State may not impose any
tax on the dividends paid by the company, except insofar as such dividends are paid to a
resident of that other Contracting State or insofar as the holding in respect of which the
dividends are paid is effectively connected with a permanent establishment situated in
that other Contracting State, nor subject the company's undistributed profits to a tax on
the company's undistributed profits, even if the dividends paid or the undistributed profits
consist wholly or partly of profits or income arising in such other Contracting State.
ARTICLE 11
INTEREST
2. However, interest 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 interest is a resident of the other Contracting State, the tax so charged shall
not exceed:
1. Interest arising in a Contracting State and paid to a resident of the other
Contracting State may be taxed in that other Contracting State.
(a) 5 per cent of the gross amount of the interest if:
(i) the beneficial owner of the interest is a bank, an insurance
company or a securities dealer;
(ii) the beneficial owner of the interest is a recognised pension fund,
provided that such interest is derived from the activities referred to
in clause (i) or (ii) of subparagraph (1) of paragraph 1 of Article 3;
Or
(iii) the interest is paid with respect to debt-claims arising as a part of
the sale of equipment or merchandise, or the provision of services,
on credit by a resident of that other Contracting State;
(b) 10 per cent of the gross amount of the interest in all other cases
(a) the interest is beneficially owned 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; or
(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.
3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting
State shall be taxable only in the other Contracting State if:
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