二国間租税条約の仲裁手続に関する議定書（条文及び署名部分）
令和7年7月4日|p.41
左の本文を選ぶと、右側の官報原文画像で該当箇所を照合できます。
() The mutual agreement that implements the arbitration decision on
the case shall be considered not to be accepted by a person directly
affected by the case if any person directly affected by the case does
not, within 60 days after the date on which notification of the
mutual agreement is sent to the person, withdraw all issues
resolved in the mutual agreement implementing the arbitration
decision from consideration by any court or administrative tribunal
or otherwise terminate any pending court or administrative
proceedings with respect to such issues in a manner consistent with
that mutual agreement.
(e) For the purposes of Article 23 of the Convention and this paragraph, the
arbitration proceedings, as well as, in the case of clauses (i) and (ii), the
mutual agreement procedure, with respect to a case shall terminate if, at
any time after the request for arbitration has been made and before the
arbitration panel has delivered its decision to the competent authorities of
the Contracting States:
(i) the competent authorities of the Contracting States reach a mutual
agreement to resolve the case pursuant to paragraph 2 of Article 23
of the Convention;
(ii) the person who presented the case withdraws the request for
arbitration or the request for the mutual agreement procedure; or
(ii) a decision concerning the unresolved issues arising from the case
is rendered by a court or administrative tribunal of one of the
Contracting States.
(f) Each of the competent authorities of the Contracting States shall bear its
own expenses and those of its appointed arbitrator. Unless otherwise
agreed by the competent authorities of the Contracting States, the cost of
the Chair of the arbitration panel and other expenses associated with the
conduct of the arbitration proceedings shall be borne by the competent
authorities of the Contracting States in equal shares.
the and the the the the the the the the the the the the the the the the and the the the the the the
(g) The provisions of paragraph 5 of Article 23 of the Convention and this
paragraph shall not apply to cases falling within paragraph 3 of Article 4
of the Convention.
IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their
respective Governments, have signed this Protocol.
DONE in duplicate at Tokyo this nineteenth day of February, 2024, in the Japanese.
Ukrainian and English languages, all texts being equally authentic. In case of any
divergence of interpretation, the English text shall prevail.
For the Government of Japan:
For the Government of Ukraine:
K. Matsu
Marchenko