その他令和7年10月31日
租税条約における相互合意手続（第24条）
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令和7年10月31日
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号外
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p.31
号外p.31
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3. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11,
paragraph 6 of Article 12 or paragraph 3 of Article 21 apply, interest, royalties and other
disbursements paid by an enterprise of a Contracting State to a resident of the other
Contracting State shall, for the purpose of determining the taxable profits of such
enterprise, be deductible under the same conditions as if they had been paid to a resident
of the first-mentioned Contracting State.
4. Enterprises of a Contracting State, the capital of which is wholly or partly owned
or controlled, directly or indirectly, by one or more residents of the other Contracting
State, shall not be subjected in the first-mentioned Contracting State to any taxation or
any requirement connected therewith which is other or more burdensome than the
taxation and connected requirements to which other similar enterprises of the first-
mentioned Contracting State are or may be subjected
5. The provisions of this Article shall, notwithstanding the provisions of Article 2,
apply to taxes of every kind and description imposed on behalf of a Contracting State or
of its political subdivisions or local authorities.
ARTICLE24
MUTUAL AGREEMENT PROCEDURE
1. Where a person considers that the actions of one or both of the Contracting States
result or will result for him in taxation not in accordance with the provisions of this
Convention, he may, irrespective of the remedies provided by the domestic law of those
Contracting States, present his case to the competent authority of either Contracting State.
The case must be presented within three years from the first notification of the action
resulting in taxation not in accordance with the provisions of the Convention.
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2. The competent authority shall endeavour, if the objection appears to it to be
justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case
by mutual agreement with the competent authority of the other Contracting State, with a
view to the avoidance of taxation which is not in accordance with the provisions of this
Convention. Any agreement reached shall be implemented notwithstanding any time
limits in the domestic law of the Contracting States.
3. The competent authorities of the Contracting States shall endeavour to resolve by
mutual agreement any difficulties or doubts arising as to the interpretation or application
of this Convention. They may also consult together for the elimination of double
taxation in cases not provided for in the Convention.
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4. The competent authorities of the Contracting States may communicate with each
other directly, including through a joint commission consisting of themselves or their
representatives, for the purpose of reaching an agreement in the sense of the preceding
paragraphs of this Article.
5. Where.
(a)
) under paragraph 1, a person has presented a case to the competent
authority of a Contracting State on the basis that the actions of one or both
of the Contracting States have resulted for that person in taxation not in
accordance with the provisions of this Convention, and
(b)
) the competent authorities are unable to reach an agreement to resolve that
case pursuant to paragraph 2 within two years from the date when all the
information required by the competent authorities in order to address the
case has been provided to both competent authorities.
any unresolved issues arising from the case shall be submitted to arbitration if the person
so requests in writing. These unresolved issues shall not, however, be submitted to
arbitration if a decision on these issues has already been rendered by a court or
administrative tribunal of either Contracting State. Unless a person directly affected by
the case does not accept the mutual agreement that implements the arbitration decision,
that decision shall be binding on both Contracting States and shall be implemented
notwithstanding any time limits in the domestic laws of these Contracting States. The
competent authorities of the Contracting States shall by mutual agreement settle the mode
of application of this paragraph.
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