その他令和7年10月31日

租税条約における相互協議手続、仲裁及び情報交換に関する規定

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令和7年10月31日

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p.33 - p.34

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租税条約における相互協議手続、仲裁及び情報交換に関する規定

令和7年10月31日|p.33-34

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(b) The arbitration decision shall not be binding on both Contracting States, if

a final decision of the courts of one of the Contracting States holds that the

arbitration decision is invalid. In such a case, the request for arbitration

under paragraph 5 shall be considered not to have been made, and the

arbitration proceedings shall be considered not to have taken place (except

for the purposes of subparagraphs (b) and (c) of paragraph 7, and

paragraph 11). In such a case, a new request for arbitration may be made

unless the competent authorities of the Contracting States agree that such

a new request should not be permitted

(b) the person who presented the case withdraws the request for arbitration or

the request for the mutual agreement procedure; or

rendered by a court or administrative tribunal of one of the Contracting

States

9. (a) If a person directed by the case does not the mutual

11. Each of the competent authorities of the Contracting States shall bear its own

agreement that implements the arbitration decision, the case shall not be

expenses and those of its appointed arbitrator. Unless otherwise agreed by the

eligible for any further consideration by the competent authorities of the

competent authorities of the Contracting States, the cost of the Chair of the arbitration

Contracting States.

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.

(b) The mutual agreement that implements the arbitration decision on the case

12. The provisions of paragraphs 5 to 11 shall not apply to cases falling within

case if any person directly affected by the case does not, within 60 days

paragraph 3 of Article 4.

after the date on which notification of the mutual agreement is sent to the

Marker Maresthe the the the the the the the the the the the the the the the the the and the ing the and the theMarter Proment of the the the19,4

person, withdraw all issues resolved in the mutual agreement

ARTICLE 25

implementing the arbitration decision from consideration by any court or

EXCHANGE OF INFORMATION

administrative tribunal or otherwise terminate any pending court or

administrative proceedings with respect to such issues in a manner

1. The competent authorities of the Contracting States shall exchange such

consistent with that mutual agreement

information as is foreseeably relevant for carrying out the provisions of this Convention

or to the administration or enforcement of the domestic laws concerning taxes of every

10.For the purposes of this Article, the arbitration proceedings, as well as, in the case

kind and description imposed on behalf of the Contracting States, or of their political

of subparagraphs (a) and (b), the mutual agreement procedure, with respect to a case shall

subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the

terminate if, at any time after the request for arbitration has been made and before the

Convention. The exchange of information is not restricted by Articles 1 and 2.

arbitration panel has delivered its decision to the competent authorities of the Contracting

States:

(a) the competent authorities of the Contracting States reach a mutual

agreement to resolve the case pursuant to paragraph 2;

2. Any information received under paragraph 1 by a Contracting State shall be

5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting

treated as secret in the same manner as information obtained under the domestic laws of

State to decline to supply information solely because the information is held by a bank,

that Contracting State and shall be disclosed only to persons or authorities (including

other financial institution, nominee or person acting in an agency or a fiduciary capacity

courts and administrative bodies) concerned with the assessment or collection of, the

or because it relates to ownership interests in a person.

enforcement or prosecution in respect of, the determination of appeals in relation to the

taxes referred to in paragraph 1, or the oversight of the above. Such persons or

ARTICLE 26

authorities shall use the information only for such purposes. They may disclose the

ASSISTANCE IN THE COLLECTION OF TAXES

information in public court proceedings or in judicial decisions. Notwithstanding the

foregoing, information received by a Contracting State may be used for other purposes

1. The Contracting States shall lend assistance to each other in the collection of

when such information may be used for such other purposes under the laws of both

revenue claims. This assistance is not restricted by Articles 1 and 2. The competent

Contracting States and the competent authority of the Contracting State supplying the

authorities of the Contracting States may by mutual agreement settle the mode of

information authorises such use.

application of this Article.

3. In no case shall the provisions of paragraphs 1 and2be construed so as to impose

2. The term "revenue claim" as used in this Article means an amount owed in respect

on a Contracting State the obligation:

of the following taxes, insofar as the taxation thereunder is not contrary to this Convention

or any other instrument to which the Contracting States are parties, as well as interest.

(a) to carry out administrative measures at variance with the laws and

administrative penalties and costs of collection or conservancy related to such amount:

administrative practice of that or of the other Contracting State:

(a) in Japan:

(b) to supply information which is not obtainable under the laws or in the

normal course of the administration of that or of the other Contracting

(i) the taxes referred to in clauses (i) to (iv) of subparagraph (a) of

State;

paragraph 3 of Article 2;

() the special corporation tax for reconstruction;

commercial or professional secret or trade process, or information the

disclosure of which would be contrary to public policy.

(iiii) the consumption tax;

4. If information is requested by a Contracting State in accordance with this Article.

(iv) the local consumption tax;

the other Contracting State shall use its information gathering measures to obtain the

000000000000000000000000000000000000000000000000000Comple the and the the and the andMare Com the the the the the the

requested information, even though that other Contracting State may not need such

(v) the inheritance tax; and

information for its own tax purposes. The obligation contained in the preceding

sentence is subject to the limitations of paragraph 3 but in no case shall such limitations

(vi) the gift tax;

be construed to permit a Contracting State to decline to supply information solely because

(b) in Tuder.

it has no domestic interest in such information

(b) in Turkmenistan:

p.33 / 2

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