その他令和7年11月21日

条約（アルメニア共和国と日本国間の租税に関する協定）の定義等

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令和7年11月21日

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条約（アルメニア共和国と日本国間の租税に関する協定）の定義等

令和7年11月21日|p.15-16

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4. This Convention shall apply also to any identical or substantially similar taxes that

are imposed after the date of signature of the Convention in addition to, or in place of, the

existing taxes. The competent authorities of the Contracting States shall notify each

other of any significant changes that have been made in their taxation laws.

ARTICLE3

GENERAL DEFINITIONS

1. For the purposes of this Convention, unless the context otherwise requires:

(a) the term "Armenia" means the Republic of Armenia and, when used in a

geographical sense, means the territory of the Republic of Armenia,

including land, waters, subsoil and air space, upon which the Republic of

Armenia exercises its sovereign rights and jurisdiction according to its

national legislation and international law;

(b) the term "Japan", when used in a geographical sense, means all the

territory of Japan, including its territorial sea, in which the laws relating to

Japanese tax are in force, and all the area beyond its territorial sea.

including the seabed and subsoil thereof, over which Japan has sovereign

rights in accordance with international law and in which the laws relating

to Japanese tax are in force;

Japan or Armenia, as the context requires;

(d) the term "person" includes an individual, a company and any other body

of persons;

(e) the term "company" means any body corporate or any entity that is treated

as a body corporate for tax purposes;

(f) the term "enterprise" applies to the carrying on of any business;

(g) the terms "enterprise of a Contracting State" and "enterprise of the other

Contracting State' mean respectively an enterprise carried on by a resident

of a Contracting State and an enterprise carried on by a resident of the

other Contracting State;

(h) the term "international traffic" means any transport by a ship or aircraft

except when the ship or aircraft is operated solely between places in a

Contracting State and the enterprise that operates the ship or aircraft is not

an enterprise of that Contracting State;

(i) term "competent authority means:

(i) in Armenia, the Ministry of Finance and State Revenue Committee

or their authorised representatives;

(ii) in Japan, the Minister of Finance or his or her authorised

representative;

(1) the term "national", in relation to a Contracting State, means:

(1) any individual possessing the nationality or citizenship of that

Contracting State; and

(ii) legal person, partnership or associatiation deriving its status as

such from the laws in force in that Contracting State;

(k) the term "business" includes the performance of professional services and

of other activities of an independent character;

(1) the term "recognised pension fund" of a Contracting State means an entity

or arrangement established under the law of that Contracting State that is

treated as a separate person under the taxation laws of that Contracting

State and:

(i) that is established and operated exclusively or almost exclusively

to administer or provide retirement benefits and ancillary or

incidental benefits or other similar remuneration to individuals and

that is regulated as such by that Contracting State or one of its

political subdivisions or local authorities; or

(ii) that is established and operated exclusively or almost exclusively

to invest funds for the benefit of other recognised pension funds of

that Contracting State.

Where an entity or arrangement established under the law of a Contracting

State would constitute a recognised pension fund under clause (i) or (ii) if

it were treated as a separate person under the taxation laws of that

Contracting State, it shall be considered, for the purposes of the

Convention, as a separate person treated as such under the taxation laws

of that Contracting State and all the assets and income of the entity or

arrangement shall be treated as assets held and income derived by that

separate person and not by another person.

2. As regards the application of this Convention at any time by a Contracting State.

any term not defined therein shall, unless the context otherwise requires or the competent

authorities agree to a different meaning pursuant to the provisions of Article 24, have the

meaning that it has at that time under the law of that Contracting State for the purposes

of the taxes to which the Convention applies, any meaning under the applicable tax laws

of that Contracting State prevailing over a meaning given to the term under other laws of

that Contracting State.

ARTICLE 4

RESIDENT

1. For the purposes of this Convention, the term "resident of a Contracting State"

means any person who, under the laws of that Contracting State, is liable to tax therein

by reason of his domicile, residence, place of incorporation, place of head or main office.

place of management or any other criterion of a similar nature, and also includes that

Contracting State and any political subdivision or local authority thereof as well as a

recognised pension fund of that Contracting State. This term, however, does not include

any person who is liable to tax in that Contracting State in respect only of income from

sources in that Contracting State.

2. Where by reason of the provisions of paragraph 1 an individual0.0a resident of

both Contracting States, then his status shall be determined as follows:

(a) he shall be deemed to be a resident only of the Contracting State in which

he has a permanent home available to him; if he has a permanent home

available to him in both Contracting States, he shall be deemed to be a

resident only of the Contracting State with which his personal and

economic relations are closer (centre of vital interests):

(b) if the Contracting State in which he has his centre of vital interests cannot

be determined, or if he has not a permanent home available to him in either

Contracting State, he shall be deemed to be a resident only of the

Contracting State in which he has an habitual abode:

he shall be deemed to be a resident only of the Contracting State of which

he is a national:

(d) if he is a national of both Contracting States or of neither of them, the

competent authorities of the Contracting States shall settle the question by

mutual agreement.

p.15 / 2

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