その他令和7年10月31日
租税条約 第9条（関連企業）
掲載日
令和7年10月31日
号種
号外
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p.24 - p.25
号外p.24-p.25
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ARTICLE9
ASSOCIATED ENTERPRISES
1. Where
(a) an enterprise of a Contracting State participates directly or indirectly in
the management, control or capital of an enterprise of the other
Contracting State, or
(b) the same persons participate directly or indirectly in the management,
control or capital of an enterprise of a Contracting State and an enterprise
of the other Contracting State.
and in either case conditions are made or imposed between the two enterprises in their
commercial or financial relations which differ from those which would be made between
independent enterprises, then any profits which would, but for those conditions, have
accrued to one of the enterprises, but, by reason of those conditions, have not so accrued,
may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that
Contracting State - and taxes accordingly - profits on which an enterprise of the other
Contracting State has been charged to tax in that other Contracting State and the profits
so included are profits which would have accrued to the enterprise of the first-mentioned
Contracting State if the conditions made between the two enterprises had been those
which would have been made between independent enterprises, then that other
Contracting State shall make an appropriate adjustment to the amount of the tax charged
therein on those profits. In determining such adjustment, due regard shall be had to the
other provisions of this Convention and the competent authorities of the Contracting
States shall if necessary consult each other.
ARTICLE 10
DIVIDENDS
1. Dividends paid by a company which is a resident of a Contracting State to a
resident of the other Contracting State may be taxed in that other Contracting State.
2. However, dividends paid by a company which is a resident of 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 dividends is a resident of the other Contracting State,
the tax so charged shall not exceed 10 per cent of the gross amount of the dividends.
3. Notwithstanding the provisions of paragraph 2, dividends paid by a company
which is a resident of a Contracting State shall be taxable only in the other Contracting
State if the beneficial owner of the dividends is a resident of that other Contracting State
and is a company which has owned directly or indirectly, throughout a six month period
that includes the date on which entitlement to the dividends is determined (for the purpose
of computing that period, no account shall be taken of changes of ownership that would
directly result from a corporate reorganisation, such as a merger or divisive reorganisation,
of the company that is the beneficial owner of the dividends or that pays the dividends),
at least 25 per cent of:
(a) in the case where the company paying the dividends is a resident of Japan,
the voting power of that company;
(b) in the case where the company paying the dividends is a resident of
Turkmenistan, the capital of that company.
4. Notwithstanding the provisions of paragraph 3, where dividends paid by a
company which is a resident of a Contracting State are deductible in computing the
taxable income of that company in that Contracting State, such dividends may be taxed
in that Contracting State according to the laws of that Contracting State, but if the
beneficial owner of the dividends is a resident of the other Contracting State, the tax so
charged shall not exceed 10 per cent of the gross amount of the dividends.
VI
company in respect of the profits out of which the dividends are paid.
11The provisions of paragraphs 2, 3 and 4 shall not affect the taxation of the
5. The term "dividends" as used in this Article means income from shares,
"jouissance" shares or "jouissance" rights, mining shares, founders'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.
11
. The provisions of paragraphs 1,2,3,3 and 4 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.
00
Where a company which which5.a 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.
p.24 / 2
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