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23th, Amended Japan-Switzerland Tax Treaty Signed, Albert Einstein

June 21, 2010

1. Taxation (Source: “Zeimu Tsushin Magazine”)

 

Ministry of Finance Japan announced on its website that Japan and Switzerland had signed a protocol amending their Tax Treaty.

It is scheduled to enter into force after Diet approval and domestic procedures.

 

 The main points of the amendments to the existing treaty are as follows:

 

 1)     Provision on the exchange of information

    The new provision will allow Switzerland, which has been committed to protecting the privacy of bank clients, to exchange banking information with its counterparts in not only criminal cases but also tax related   

    matters.

 

 2) Reduced rates and exemption to investment income

   

       Dividend

   Stocks held at 50% or more  : Tax exemption

   Stocks held at 10% or more  :5%

 

   Royalty

   Tax exemption 

 

 3) Limitation on benefit

   LOB clause similar to that in the Japan-US Tax Treaty is included in the new treaty.

 

 4) Adjustment on the taxation of pass-through entity

   The residence-country taxation has been adjusted with respect to LLC and partnership.

 

 5) TK(Tokumei Kumiai) Dividend

   The new provision will allow a source country to tax TK dividend.

 

2. Accounting

        No topics in this issue for Accounting.

 

 

3. This Week’s Words of Wisdom (Source: “English words of wisdom to enrich life”)

 

      “Personality is shaped by one’s work and accomplishment, not by flowery speech”

       (Albert Einstein)

 

       I guess that politicians and persons of integrity had better chemistry in the past, but they really mix like oil and water in these days.

       I think that the bad habit in recent years of giving up halfway through is pervading the society as a whole.

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