日本国政府とアルメニア共和国政府との間の所得税に関する二重課税の排除及び脱税の防止に関する条約（署名文及び附属書）
令和7年11月21日|p.32
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PROTOCOL
(b) with respect to taxes levied not on the basis of a taxable year, for taxes
levied on or after 1 January in the calendar year next following that in
which the notice is given.
IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their
respective Governments, have signed this Convention.
DONE in duplicate at Yerevan this twenty-sixth day of December, 2024, in the
Japanese, Armenian and English languages, all texts being equally authentic. In case of
any divergence of interpretation, the English text shall prevail
For Forthitictro
Juhh Wth Whibhublhublhublhh <nd
At the signing of the Convention between Japan and the Republic of Armenia for
the Elimination of Double Taxation with respect to Taxes on Income and the Prevention
of Tax Evasion and Avoidance (hereinafter referred to as "the Convention"), Japan and
the Republic of Armenia have agreed upon the following provisions which shall form an
integral part of the Convention.
1. With reference to Article 5 of the Convention:
It is understood that each of the places of business listed in paragraph 2 of Article
5 of the Convention constitutes a permanent establishment as defined in paragraph 1 of
that Article only if it meets the requirements of paragraph 1 of that Article.
2. With reference to Article 11 of the Convention:
If, after the date of signature of the Convention, Armenia concludes an agreement
with a third jurisdiction containing provisions which limit taxation in Armenia on an item
of income described in paragraph 2 of Article 11 of the Convention to a rate of tax lower
than that provided for in that paragraph or exempt such item of income from tax in
Armenia, the Contracting States shall, at the request of Japan, enter into negotiations with
a view to incorporating such lower rate of tax or exemption from tax into the Convention.
The competent authority of Armenia shall notify the competent authority of Japan of such
event immediately after it has happened.
3. With reference to paragraph 5 of Article 24 of the Convention: