法律令和8年7月1日
租税条約（二重課避防止に関する協定）第24条および第25条
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租税条約（二重課避防止に関する協定）第24条および第25条
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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 Agreement. They may also consult together for the elimination of double
taxation in cases not provided for in the Agreement.
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.
ARTICLE 24
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 Agreement
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 or
administrative subdivisions or local authorities, insofar as the taxation thereunder is not
contrary to the Agreement. The exchange of information is not restricted by Articles 1
and 2.
2. Any information received under paragraph 1 by a Contracting State shall be
treated as secret in the same manner as information obtained under the domestic laws of
that Contracting State and shall be disclosed only to persons or authorities (including
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
taxes referred to in paragraph 1, or the oversight of the above. Such persons or
authorities shall use the information only for such purposes. They may disclose the
information in public court proceedings or in judicial decisions. Notwithstanding the
foregoing, information received by a Contracting State may be used for other purposes
when such information may be used for such other purposes under the laws of both
Contracting States and the competent authority of the Contracting State supplying the
information authorises such use.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose
on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and
administrative practice of that or of the other Contracting State;
(b) to supply information which is not obtainable under the laws or in the
normal course of the administration of that or of the other Contracting
State;
(c) to supply information which would disclose any trade, business, industrial,
commercial or professional secret or trade process, or information the
disclosure of which would be contrary to public policy.
4. If information is requested by a Contracting State in accordance with this Article.
the other Contracting State shall use its information gathering measures to obtain the
requested information, even though that other Contracting State may not need such
information for its own tax purposes. The obligation contained in the preceding
sentence is subject to the limitations of paragraph 3 but in no case shall such limitations
be construed to permit a Contracting State to decline to supply information solely because
it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting
State to decline to supply information solely because the information is held by a bank.
other financial institution, nominee or person acting in an agency or a fiduciary capacity
or because it relates to ownership interests in a person.
ARTICLE 25
MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS
Nothing in this Agreement shall affect the fiscal privileges of members of
diplomatic missions or consular posts under the general rules of international law or under
the provisions of special agreements.
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