その他令和7年7月4日

条約第25条（税金の徴収に関する援助）

号外p.34 - p.35

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条約第25条（税金の徴収に関する援助）

令和7年7月4日|p.34-35

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ARTICLE 25

ASSISTANCE IN THE COLLECTION OF TAXES

1. The Contracting States shall lend assistance 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 Japan:

(i) the taxes referred to in clauses (i) to (iv) of subparagraph (a) of

paragraph 3 of Article 2;

(ii) special corporporation tax for reconstruction;

(ili) the consumption tax;

(iv) tax;

(v) theritand

(vi) the gift tax;

(b) in Ukraine:

(i) the taxes referred to in subparagraph (b) of paragraph 3 of Article

() the value added tax;

(ii) payment;

(iv) the environment tax;

(v) the property tax;

(vi) the excise tax; and

(vi) the single tax;

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

. 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.

p.34 / 2

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