その他令和8年7月1日
租税に関する二重課避の防止に関する協定（第26条〜第49条）
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租税に関する二重課避の防止に関する協定（第26条〜第49条）
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ARTICLE 26
ENTITLEMENT TO BENEFITS
Notwithstanding the other provisions of this Agreement, a benefit under the
Agreement shall not be granted in respect of an item of income if it is reasonable to
conclude, having regard to all relevant facts and circumstances, that obtaining that benefit
was one of the principal purposes of any arrangement or transaction that resulted directly
or indirectly in that benefit, unless it is established that granting that benefit in these
circumstances would be in accordance with the object and purpose of the relevant
provisions of the Agreement
ARTICLE 27
AMENDMENT
This Agreement may be amended by agreement between the Contracting States.
ARTICLE 28
ENTRY INTO FORCE
1. Each of the Contracting States shall send in writing and through diplomatic
channels to the other Contracting State the notification confirming that its internal
procedures necessary for the entry into force of this Agreement have been completed.
The Agreement shall enter into force on the thirtieth day after the date of receipt of the
latter notification.
2. This Agreement shall have effect:
(a) in Japan:
(i) with respect to taxes levied on the basis of a taxable year, for taxes
for any taxable years beginning on or after the first day of January
of the calendar year next following the year in which the
Agreement enters into force;
(ii) with respect to taxes levied not on the basis of a taxable year, for
taxes levied on or after the first day of January of the calendar year
next following the year in which the Agreement enters into force;
(b) Kyrgyz Republic:
(i) with respect to taxes withheld at source, for amounts paid or
credited on or after the first day of January of the calendar year
next following the year in which the Agreement enters into force;
(ii) with respect to other taxes, for taxes for taxable years beginning
on or after the first day of January of the calendar year nex
following the year in which the Agreement enters into force.
3. Notwithstanding the provisions of paragraph 2, the provisions of Article 24 shall
have effect from the date of entry into force of this Agreement without regard to the date
on which the taxes are levied or the taxable year to which the taxes relate.
ARTICLE 29
TERMINATION
This Agreement shall remain in force until terminated by a Contracting State.
Either Contracting State may terminate the Agreement by giving notice of termination
through diplomatic channels to the other Contracting State at least six months before the
end of any calendar year beginning after expiry of five years from the date of entry into
force of the Agreement. In such event, the Agreement shall cease to have effect:
(a) in Japan:
(i) with respect to taxes levied on the basis of a taxable year, for taxes
for any taxable years beginning on or after the first day of January
of the calendar year next following the year in which the notice is
given;
(ii) with respect taxes levied not on the basis of a taxable year, for
taxes levied on or after the first day of January of the calendar yea
next following the year in which the notice is given;
(b) in the Kyrgyz Republic:
(i) with respect to taxes withheld at source, for amounts paid or
credited on or after the first day of January of the calendar year
next following the year in which the notice is given;
(ii) with respect to other taxes, for taxes for taxable years beginning
on or after the first day of January of the calendar year next
following the year in which the notice is given.
IN WITNESS WHEREOF the undersigned, being duly authorised thereto, have
signed this Agreement.
DONE in duplicate at Tokyo this nineteenth day of December, 2025, in the
Japanese, Kyrgyz, Russian and English languages, all texts being equally authentic. In
case of any divergence of interpretation, the English text shall prevail.
For Kyz Republic
茂木敏充B.ChisHKOB
p.74 / 2
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