その他令和7年11月21日
租税条約（配当および利子に関する規定）
掲載日
令和7年11月21日
号種
号外
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p.21 - p.22
号外p.21-p.22
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7. The provisions of paragraphs 1, 2, 3 and 4 shall not apply if the beneficial owner
of the dividends, being a resident of a Contracting State, carries on business in the other
Contracting State of which the company paying the dividends is a resident through a
permanent establishment situated therein and the holding in respect of which the
dividends are paid is effectively connected with such permanent establishment. In such
case the provisions of Article 7 shall apply.
8.Where a company which is a resident of a Contracting State derives profits or
income from the other Contracting State, that other Contracting State may not impose any
tax on the dividends paid by the company, except insofar as such dividends are paid to a
resident of that other Contracting State or insofar as the holding in respect of which the
dividends are paid is effectively connected with a permanent establishment situated in
that other Contracting State, nor subject the company's undistributed profits to a tax on
the company's undistributed profits, even if the dividends paid or the undistributed profits
consist wholly or partly of profits or income arising in such other Contracting State.
ARTICLE 11
INTEREST
1. Interest arising in a Contracting State and paid to a resident of the other
Contracting State may be taxed in that other Contracting State.
2. However, interest arising in 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 interest is a resident of the other Contracting State, the tax so charged shall
not exceed 5 per cent of the gross amount of the interest.
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3. Notwithstanding the provisions of paragraph 2, interest arising in a Contracting
State shall be taxable only in the other Contracting State if:
(a) the interest is beneficially owned by that other Contracting State, a
political subdivision or local authority thereof, the central bank of that
other Contracting State or any institution wholly owned by that other
Contracting State or a political subdivision or local authority thereof; or
(b)
b) the interest is beneficially owned by a resident of that other Contracting
State with respect to debt-claims guaranteed, insured or indirectly financed
by that other Contracting State, a political subdivision or local authority
thereof, the central bank of that other Contracting State or any institution
wholly owned by that other Contracting State or a political subdivision or
local authority thereof.
4. The term "interest" as used in this Article means income from debt-claims of
every kind, whether or not secured by mortgage and whether or not carrying a right to
participate in the debtor's profits, and in particular, income from government securities
and income from bonds or debentures, including premiums and prizes attaching to such
securities, bonds or debentures as well as other income that is subjected to the same
taxation treatment as income from money lent by the laws of the Contracting State in
which the income arises. Income dealt with in Article 10 and penalty charges for late
payment shall not be regarded as interest for the purposes of this Article.
5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of
the interest, being a resident of a Contracting State, carries on business in the other
Contracting State in which the interest arises through a permanent establishment situated
therein and the debt-claim in respect of which the interest is paid is effectively connected
with such permanent establishment. In such case the provisions of Article 7 shall apply.
19
Interest shall be deemed to arise in a Contracting State when the payer is a resident
of that Contracting State. Where, however, the person paying the interest, whether he is
a resident of a Contracting State or not, has in a Contracting State a permanent
establishment in connection with which the indebtedness on which the interest is paid
was incurred, and such interest is borne by such permanent establishment, then such
interest shall be deemed to arise in the Contracting State in which the permanent
establishment is situated
7. 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 interest, having
regard to the debt-claim for which it is paid, 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 payments shall remain taxable according to the laws of each
Contracting State, due regard being had to the other provisions of this Convention.
ARTICLE 12
ROYALTIES
1. Royalties arising in a Contracting State and paid to a resident of the other
Contracting State may be taxed in that other Contracting State.
2. However, royalties arising in 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 royalties is a resident of the other Contracting State, the tax so charged shall
not exceed 5 per cent of the gross amount of the royalties.
3. The term "royalties" as used in this Article means payments of any kind received
as a consideration for the use of, or the right to use, any copyright of literary, artistic or
scientific work including cinematograph films, or any patent, trade mark, design or model.
plan, or secret formula or process, or for information concerning industrial, commercial
or scientific experience.
4. The provisions of paragraphs 1 and2 shall not apply if the beneficial owner of the
royalties, being a resident of a Contracting State, carries on business in the other
Contracting State in which the royalties arise through a permanent establishment situated
therein and the right or property in respect of which the royalties are paid is effectively
connected with such permanent establishment. In such case the provisions of Article 7
shall apply.
5. Royalties shall be deemed to arise in a Contracting State when the payer0.00.0
resident of that Contracting State. Where, however, the person paying the royalties,
whether he is a resident of a Contracting State or not, has in a Contracting State a
permanent establishment in connection with which the liability to pay the royalties was
incurred, and such royalties are borne by such permanent establishment, then such
royalties shall be deemed to arise in the Contracting State in which the permanent
establishment is situated.
6. 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 royalties, having
regard to the use, right or information for which they are paid, 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 payments shall remain taxable according to
the laws of each Contracting State, due regard being had to the other provisions of this
Convention.
ARTICLE 13
CAPITAL GAINS
1. Gains derived by a resident of a Contracting State from the alienation of
immovable property referred to in Article 6 and situated in the other Contracting State
may be taxed in that other Contracting State.
2. Gains from the alienation of any property, other than immovable property referred
to in Article 6, forming part of the business property of a permanent establishment which
an enterprise of a Contracting State has in the other Contracting State, including such
gains from the alienation of such a permanent establishment (alone or with the whole
enterprise), may be taxed in that other Contracting State
3. Gains that an enterprise of a Contracting State that operates ships or aircraft in
international traffic derives from the alienation of such ships or aircraft, or of any property,
other than immovable property referred to in Article 6, pertaining to the operation of such
ships or aircraft, shall be taxable only in that Contracting State.
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