その他令和7年7月4日

日本国政府とウクライナ共和国政府との間の租税条約（二重課税防止協定）抜粋

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日本国政府とウクライナ共和国政府との間の租税条約（二重課税防止協定）抜粋

令和7年7月4日|p.32

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ARTICLE 20

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 21

ELIMINATION OF DOUBLE TAXATION

1. In Japan, double taxation shall be eliminated as follows:

Subject to the provisions of the laws of Japan regarding the allowance as a credit

against Japanese tax of tax payable in any country other than Japan, where a resident of

Japan derives income from Ukraine which may be taxed in Ukraine in accordance with

the provisions of this Convention, the amount of Ukrainian tax payable in respect of that

income shall be allowed as a credit against the Japanese tax imposed on that resident.

The amount of credit, however, shall not exceed the amount of the Japanese tax which is

appropriate to that income.

2. In Ukraine, double taxation shall be eliminated as follows:

(a) Where a resident of Ukraine derives income which, in accordance with the

provisions of this Convention, may be taxed in Japan, Ukraine shall allow

as a deduction from the Ukrainian 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 Ukrainian tax, as computed before the

deduction is given, which is attributable to the income which may be taxed

in Japan

(b) Where in accordance with any provision of the Convention income

derived by a resident of Ukraine is exempt from tax in Ukraine, Ukraine

may nevertheless, in calculating the amount of tax on the remaining

income of such resident, take into account the exempted income.

ARTICLE 22

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.

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