Japan and the UK exchange notes concerning article 7 (“business profits”) of the Japan-UK Tax Convention

On July 23, 2015 the Japanese Ministry of Finance issued a press release announcing that on July 22, 2015 the Government of Japan and the Government of the United Kingdom exchanged notes concerning Article 7 of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains as amended by Article 2 of the Protocol which entered into force on December 12, 2014.

According to the press release through the exchange of the notes, both Governments agreed that the provisions of Article 7, as amended by Article 2 of the Protocol, shall be applicable: (a)in Japan, with respect to profits for any taxable year beginning on or after 1 April 2016; and (b) in the United Kingdom, (i)in respect of profits charged to income tax or capital gains tax, for any year of assessment beginning on or after 6 April 2016; and
(ii) in respect of profits charged to corporation tax, for any financial year beginning on or after 1 April 2016.