その他令和7年7月4日

給付の権利に関する規定（第27条）

号外p.36 - p.37

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公告概要

Entry into Force of the Convention

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給付の権利に関する規定（第27条）

令和7年7月4日|p.36-37

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ARTICLE 27

(b) in the case of a request under paragraph 4, a revenue claim of the first-

ENTITLEMENT TO BENEFITS

mentioned Contracting State in respect of which that Contracting State

may, under its laws, take measures of conservancy with a view to ensure

1. (a) Where

its collection

(i) an enterprise of a Contracting State derives income from the other

the competent authority of the first-mentioned Contracting State shall promptly notify the

Contracting State and the first-mentioned Contracting State treats

competent authority of the other Contracting State of that fact and, at the option of the

such income as attributable to a permanent establishment of the

competent authority of that other Contracting State, the competent authority of the first-

enterprise situated in a third jurisdiction, and

mentioned Contracting State shall either suspend or withdraw its request.

(ii) the profits attributable to that permanent establishment are exempt

9. In no case shall the provisions of this Article be construed so as to impose on a

from tax in the first-mentioned Contracting State,

Contracting State the obligation:

the benefits under this Convention shall not apply to any item of income

on which the tax in the third jurisdiction is less than 60 per cent of the tax

that would be imposed in the first-mentioned Contracting State on that

item of income if that permanent establishment were situated in the first-

mentioned Contracting State. In such a case, any income to which the

provisions of this paragraph apply shall remain taxable according to the

domestic law of the other Contracting State, notwithstanding any other

provisions of the Convention.

(b) The provisions of subparagraph (a) shall not apply if the income derived

from the other Contracting State described in that subparagraph emanates

from, or is incidental to, the active conduct of a business carried on through

the permanent establishment (other than the business of making, managing

or simply holding investments for the enterprise's own account, unless

these activities are banking, insurance or securities activities carried on by

a bank, insurance enterprise or registered securities dealer, respectively).

of subparagraph (a) with respect to an item of income derived by a resident

of a Contracting State, the competent authority of the other Contracting

State may, nevertheless, grant these benefits with respect to that item of

income if, in response to a request by such resident, such competent

authority determines that granting such benefits is justified in light of the

reasons such resident did not satisfy the requirements of subparagraphs (a)

and (b) (such as the existence of losses). The competent authority of the

Contracting State to which a request has been made under the preceding

sentence by a resident of the other Contracting State shall consult with the

competent authority of that other Contracting State before either granting

or denying the request.

2. Notwithstanding the other provisions of this Convention, a benefit under the

Convention shall not be granted in respect of an item of income if it is reasonable to

conclude, having regard to all relevant facts and circumstances, that obtaining that benefit

was one of the principal purposes of any arrangement or transaction that resulted directly

or indirectly in that benefit, unless it is established that granting that benefit in these

circumstances would be in accordance with the object and purpose of the relevant

provisions of the Convention.

ARTICLE 28

ENTRY INTO FORCE

1. Each of the Contracting States shall send in writing through diplomatic channels

to the other Contracting State the notification confirming that its internal procedures

necessary for the entry into force of this Convention have been completed. The

Convention shall enter into force on the thirtieth day after the date of receipt of the latter

notification.

2. This Convention shall have effect:

(a) in Japan:

(i) with respect to taxes levied on the basis of a taxable year, for taxes

for any taxable years beginning on or after 1 January in the

calendar year next following that in which the Convention enters

into force:

(ii) with respect taxes levied not on the basis of a taxable year, for

taxes levied on or after 1 January in the calendar year next

following that in which the Convention enters into force;

(b) in Ukraine:

(i) with respect to taxes withheld at source, for amounts paid on or

after 1 January in the calendar year next following that in which

the Convention enters into force;

p.36 / 2

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