(This note is not part of the Order)
A Convention dealing with the avoidance of double taxation and fiscal evasion between the United Kingdom and Japan (“the Convention”) is set out in the Schedule to this Order.
Article 1 of the Order provides for its citation.
Article 2 makes a declaration as to the effect and content of the arrangements set out in the Convention contained in Part 1 of the Schedule to the Order, in the Protocol contained in Part 2 of the Schedule to the Order and in the Exchange of Notes contained in Part 3 of that Schedule, and that it is expedient that those arrangements should have effect.
A detailed explanation of the Convention can be found in the Explanatory Memorandum published with the Convention.
The Convention will enter into force on the thirtieth day after the date of the later of the notifications by each country of the completion of its legislative procedures. It will take effect in the United Kingdom with respect to taxes withheld at source, to income derived on or after 1st January in the calendar year next following that in which the notice is given; with respect to income tax and capital gains tax, for any year of assessment beginning on or after 6th April in the calendar year next following that in which the notice is given; and with respect to corporation tax, for any financial year beginning on or after 1st April in the calendar year next following that date. It will take effect in Japan with respect to taxes withheld at source, for amounts taxable on or after 1st January in the calendar year next following that in which the notice is given; and with respect to taxes on income which are not withheld at source and the enterprise tax, as regards income for any taxable year beginning on or after 1st January in the calendar year next following that in which the notice is given.
The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.