wetzoeker

Nr. I Overeenkomst tussen de Regering van het Koninkrijk der Nederlanden en de Regering van Japan tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen

MINISTRY OF FOREIGN AFFAIRS

Treaty Department

DVE/VV-41777

The Hague, March 3, 1970.

Excellency,

I have the honour to refer to the Convention between the Government of the Kingdom of the Netherlands and the Government of Japan for the Avoidance of Double Taxation with respect to Taxes on Income which was signed today and to confirm, on behalf of the Government of the Kingdom of the Netherlands, the following understandings reached between the two Governments:

1. With reference to paragraph 3 of Article 11, paragraph 2 of Article 12 and paragraph 2 of Article 13 of the Convention, the two Governments agree that if Japan, in a convention with any other State, being a member of the Organisation for Economic Cooperation and Development, would limit its taxation at the source on interest, on royalties or on dividends distributed by a company to a company which owns at least 25 per cent of the voting shares of the company paying the dividends to lower rates than those provided for in the said provisions, the two Governments will undertake to review the said provisions in order to provide the same treatment.

2. With reference to paragraph 3 of Article 11 of the Convention, the two Governments, having in mind that the difference between the provisions of sub-paragraph (a) and those of sub-paragraph (b) of the said paragraph is based on the fact that in Japan the rates of tax on companies' distributed profits are substantially lower than those on companies' undistributed profits, agree to undertake the review of the said provisions in order to adapt sub-paragraph (a) to sub-paragraph (b), when the basis of such difference no longer exists.

I have further the honour to request Your Excellency to be good enough to confirm the foregoing understandings on behalf of Your Excellency's Government.

I avail myself of this opportunity to renew to Your Excellency the assurances of my highest consideration.

(sd.) J. LUNS

His Excellency

Mr. Masato Fujisaki

Ambassador extraordinary

and plenipotentiary

of Japan.

Regeling
Overeenkomst tussen de Regering van het Koninkrijk der Nederlanden en de Regering van Japan tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen
Soort
Verdrag
Geldend vanaf
16-12-1992
BWB-id
BWBV0004313
Versie
1992-12-16_0

In de hele regeling · Officiële tekst op wetten.overheid.nl