その他令和7年11月21日
租税条約における情報交換及び税金徴収に関する協力（第26条）
掲載日
令和7年11月21日
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号外
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p.27
号外p.27
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5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting
2. Any information received under paragraph 1 by a Contracting State shall be
State to decline to supply information solely because the information is held by a bank,
treated as secret in the same manner as information obtained under the domestic laws of
other financial institution, nominee or person acting in an agency or a fiduciary capacity
that Contracting State and shall be disclosed only to persons or authorities (including
or because it relates to ownership interests in a person.
courts and administrative bodies) concerned with the assessment or collection of, the
enforcement or prosecution in respect of, the determination of appeals in relation to the
ARTICLE 26
taxes referred to in paragraph 1, or the oversight of the above. Such persons or
ASSISTANCE IN THE COLLECTION OF TAXES
authorities shall use the information only for such purposes. They may disclose the
information in public court proceedings or in judicial decisions. Notwithstanding the
1. The Contracting States shall lend assistance to each other in the collection of
foregoing, information received by a Contracting State may be used for other purposes
revenue claims. This assistance is not restricted by Articles 1 and 2. The competent
when such information may be used for such other purposes under the laws of both
authorities of the Contracting States may by mutual agreement settle the mode of
Contracting States and the competent authority of the Contracting State supplying the
application of this Article.
information authorises such use
2. The term "revenue claim" as used in this Article means an amount owed in respect
3. In no case shall the provisions of paragraphs 1 and 2 construed so as to impose
of the following taxes, insofar as the taxation thereunder is not contrary to this Convention
on a Contracting State the obligation:
or any other instrument to which the Contracting States are parties, as well as interest,
administrative penalties and costs of collection or conservancy related to such amount:
(a) to carry out administrative measures at variance with the laws and
administrative practice of that or of the other Contracting State:
(a) in Armenia:
(b) to supply information which is not obtainable under the laws or in the
(i) the taxes referred to in subparagraph (a) of paragraph 3 of Article
normal course of the administration of that or of the other Contracting
2; and
State;
(ii) the value added tax;
(c) to supply information which would disclose any trade, business, industrial,
(b) in Jupand the added the and to the and the added to the
commercial or professional secret or trade process, or information the
(b) in Japan:
disclosure of which would be contrary to public policy (ordre public).
(i) the taxes referred to in clauses (i) to (iv) of subparagraph (b) of
4. If information is requested by a Contracting State in accordance with this Article,
paragraph 3 of Article 2;
the other Contracting State shall use its information gathering measures to obtain the
the the the and the the the the the the the the the the and the the and the the and the and the thePropple the and the the the and the and the and the and the andMarted Proment of the and the and the and
requested information, even though that other Contracting State may not need such
(ii) the special corporation tax for reconstruction;
information for its own tax purposes. The obligation contained in the preceding
(1) the speck the con the con for for the of the the
sentence is subject to the limitations of paragraph 3 but in no case shall such limitations
(iii) the consumption tax;
be construed to permit a Contracting State to decline to supply information solely because
it has no domestic interest in such information
(iv) the local consumption tax;
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