その他令和7年10月31日
日本国とトルクメニスタン共和国との間の租税条約（二重課避に関する部分）
掲載日
令和7年10月31日
号種
号外
原文ページ
p.30
号外p.30
出典：官報発行サイト（内閣府）の掲載情報をもとに整理しています。重要な確認は公式原文を基準にしてください。
原文確認推奨
抽出テキストだけで判断せず、必要に応じて原文画像または PDF で確認してください。
出典・注意
官報発行サイト（内閣府）の掲載情報をもとに整理しています。重要な確認は公式原文を基準にしてください。
本文と原文の対照
まず左側の本文を読み、必要な箇所だけ原文ページで確認できる構成です。
← 同日の官報に戻る
原文対照の表示オプション
日本国とトルクメニスタン共和国との間の租税条約（二重課避に関する部分）
令和7年10月31日|p.30
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。
ARTICLE 20
SILENT PARTNERSHIP
Notwithstanding any other provisions of this Convention, any income derived by
a resident of a Contracting State in respect of contributions made pursuant to a silent
partnership (in the case of Japan, Tokumei Kumiai) contract or another similar contract
may be taxed in the other Contracting State according to the laws of that other Contracting
State, provided that such income arises in that other Contracting State and is deductible
in computing the taxable income of the payer in that other Contracting State.
ARTICLE 21
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
ARTICLE22
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 Turkmenistan which may be taxed in Turkmenistan in
accordance with the provisions of this Convention, the amount of Turkmen 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 Turkmenistan, double taxation shall be eliminated as follows:
Where a resident of Turkmenistan derives income from Japan which may be taxed
in Japan in accordance with the provisions of this Convention, the amount of Japanese
tax payable in respect of that income shall be allowed as a credit against the Turkmen tax
imposed on that resident. The amount of credit, however, shall not exceed the amount
of the Turkmen tax on that income computed in accordance with the taxation laws and
regulations of Turkmenistan.
ARTICLE 23
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.
読み込み中...
テキスト領域
選択中
非公開 (PII)
関連する新着公告を見逃さないために
Pro プランでは会社名・機関名・キーワードを監視条件として保存し、新着掲載を継続確認できます。14日間無料で試せます。
監視機能の詳細を見る →