その他令和7年11月21日
日本国とアルメニア共和国との間の租税条約に関する条文（二重課税の排除及び非差別待遇）
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令和7年11月21日
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号外
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p.25 - p.26
号外p.25-p.26
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日本国とアルメニア共和国との間の租税条約に関する条文（二重課税の排除及び非差別待遇）
令和7年11月21日|p.25-26
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3. 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 income referred
to in paragraph 1 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
income shall remain taxable according to the laws of each Contracting State, due regard
being had to the other provisions of this Convention.
ARTICLE 22
ELIMINATION OF DOUBLE TAXATION
1. In Armenia, double taxation shall be eliminated as follows:
(a) Where a resident of Armenia derives income which, in accordance with
the provisions of this Convention, may be taxed in Japan, Armenia shall
allow as a deduction from the Armenian tax on the income of that resident,
an amount equal to the Japanese tax paid in Japan. Such deduction shall
not, however, exceed that part of the Armenian tax, as computed before
the deduction is given, which is attributable to the income which may be
taxed in Japan.
(b) accordance with acce with of the Convention, income
derived by a resident of Armenia is exempt from tax in Armenia, Armenia
may nevertheless, in calculating the amount of tax on the remaining
income of such resident, take into account the exempted income.
2. In Japan, double taxation shall be eliminated as follows:
Subject to the provisions of the laws of Japan regarding the allowance as a credit
against Japanese tax of tax payable in any country other than Japan, where a resident of
Japan derives income from Armenia which may be taxed in Armenia in accordance with
the provisions of this Convention, the amount of Armenian tax payable in respect of that
income shall be allowed as a credit against the Japanese tax imposed on that resident
The amount of credit, however, shall not exceed the amount of the Japanese tax which is
appropriate to that income.
ARTICLE 23
NON-DISCRIMINATION
1.Nationals of a Contracting State shall not be subjected in the other Contracting
State to any taxation or any requirement connected therewith, which is other or more
burdensome than the taxation and connected requirements to which nationals of that other
Contracting State in the same circumstances, in particular with respect to residence, are
or may be subjected. The provisions of this paragraph shall, notwithstanding the
provisions of Article 1, also apply to persons who are not residents of one or both of the
Contracting States.
2. Stateless persons who are residents of a Contracting State shall not be subjected
in the other Contracting State to any taxation or any requirement connected therewith,
which is other or more burdensome than the taxation and connected requirements to
which nationals of that other Contracting State in the same circumstances, in particular
with respect to residence, are or may be subjected.
3. The taxation on a permanent establishment which an enterprise of a Contracting
State has in the other Contracting State shall not be less favourably levied in that other
Contracting State than the taxation levied on enterprises of that other Contracting State
carrying on the same activities. The provisions of this paragraph shall not be construed
as obliging a Contracting State to grant to residents of the other Contracting State any
personal allowances, reliefs and reductions for taxation purposes on account of civil status
or family responsibilities which it grants to its own residents.
4. 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.
5. 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.
6. The provisions of this Article shall, notwithstanding the provisions of Article2.
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.
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.
C、
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.
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)
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.
ARTICLE 25
EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shall exchange such
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
kind and description imposed on behalf of the Contracting States, or of their political
subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the
Convention. The exchange of information is not restricted by Articles 1 and 2.
p.25 / 2
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