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US / Japan Tax Treaty
In January 2013, the US and Japanese governments agreed on a protocol which proposed to amend the Japan - U.S. Tax Treaty. Under the new Treaty, the major changes proposed are as follows :
  Current Proposed
Interest Qualified interest 0% In principle 0%
Others 10%
Dividends Ownership>50%
AND
Has owned 12 months or more
0% Ownership≧50%
AND
Has owned six months or more
0%
Royalties 0% 0%
The new Treaty will be officially effective when the governments of both countries approve the changes in their respective parliaments. As of September 2016, the US government has yet to pass the bill for the above amendment. The following is a summary of forms required for withholding treaty benefit for a US recipient of interest, dividends or royalties.
Form# Form Name Initial Renewal
Form 1/2/3 Application Form for Income Tax Convention Yes Yes
Form 17 Attachment Form for Limitation on Benefits Article Yes 3 yrs (public co.)
1 yr (private co.)
Certificate of Residency Yes 3 yrs (public co.)
1 yr (private co.)
A copy of Pertaining Contract Yes Yes
Where to file: The local tax office where the paying entity resides. When to file: Principally the day on or before the payment is executed. If the certificate of residency is not ready on that date, you can state the expected day of submission.
the Treaty
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