附属議定書（PROTOCOL）
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PROTOCOL
At the signing of the Agreement between Japan and the Kyrgyz Republic 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 Agreement"), Japan and the
Kyrgyz Republic have agreed upon the following provisions which shall form an integral
part of the Agreement.
Notwithstanding any provisions of the Agreement, any income derived by a
resident of a Contracting State in respect of contributions made pursuant to a silent
partnership contract or another similar contract may be taxed in the other Contracting
State according to the laws of that other Contracting State, provided that such income
arises in that other Contracting State and is deductible in computing the taxable income
of the payer in that other Contracting State. It is understood that, in the case of Japan.
the term "silent partnership contract" means Tokumei Kumiai Keiyaku provided for in
Article 535 of Chapter 4 of Part 2 of the Commercial Law (Law No. 48 of 1899) of Japan
(as it may be amended from time to time without changing the general principle thereof).
IN WITNESS WHEREOF the undersigned, being duly authorised thereto, have
signed this Protocol.
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E.Cs,IMKOB