その他令和7年11月21日
租税条約（関連企業及び配当に関する条文）
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令和7年11月21日
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ARTICLE9
ASSOCIATED ENTERPRISES
1.Where
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 5 per cent of the gross amount of the dividends.
(a) an enterprise of a Contracting State participates directly or indirectly in
3. Notwithstanding the provisions of paragraph 2, dividends paid by a company
the management, control or capital of an enterprise of the other
which is a resident of a Contracting State shall be taxable only in the other Contracting
Contracting State, or
State if the beneficial owner of the dividends is a resident of that other Contracting State
Comple the and the the the andthe the the and the the a the the the a the a the a the and the and the a the a the and the the the
and is a company which has owned directly or indirectly, throughout a 365 day period
(b) the same persons participate directly or indirectly in the management,
that includes the date on which entitlement to the dividends is determined (for the purpose
control or capital of an enterprise of a Contracting State and an enterprise
of computing that period, no account shall be taken of changes of ownership that would
of the other Contracting State,
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),
and in either case conditions are made or imposed between the two enterprises in their
at least 25 per cent of:
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
(a) in the case where the company paying the dividends is a resident of
accrued to one of the enterprises, but, by reason of those conditions, have not so accrued,
Armenia, the capital of that company;
may be included in the profits of that enterprise and taxed accordingly.
(b) in the case where the company paying the dividends is a resident of Japan,
2. Where a Contracting State includes in the profits of an enterprise of that
the voting power of that company.
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
4. Notwithstanding the provisions of paragraphs 2 and 3, where dividends paid by a
so included are profits which would have accrued to the enterprise of the first-mentioned
company which is a resident of a Contracting State are deductible in computing the
Contracting State if the conditions made between the two enterprises had been those
taxable income of that company in that Contracting State, such dividends may be taxed
which would have been made between independent enterprises, then that other
in that Contracting State according to the laws of that Contracting State, but if the
Contracting State shall make an appropriate adjustment to the amount of the tax charged
beneficial owner of the dividends is a resident of the other Contracting State, the tax so
therein on those profits. In determining such adjustment, due regard shall be had to the
charged shall not exceed 10 per cent of the gross amount of the dividends.
other provisions of this Convention and the competent authorities of the Contracting
States shall if necessary consult each other.
5. The provisions of paragraphs 2, 3 and 4 shall not affect the taxation of the
company in respect of the profits out of which the dividends are paid.
6. The term "dividends" as used in this Article means income from 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.
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