Das neue Doppelbesteuerungsabkommen zwischen Japan und Deutschland: Änderungen, Neuerungen und Auswirkungen

Abstract

The new double-tax treaty (DTT) between Germany and Japan shall become effective as of January 2017. The new DTT provides especially for corporations a substantial improvement in comparison to the status quo and will increase direct investments of both countries.

Especially the reduction of withholding taxes on dividends and licenses as well as the mutual agreement procedure with binding effect will prevent the risk of double taxation in particular in connection with transfer pricing disputes in the course of tax audits.

At the same time new anti-tax-avoidance rules are introduced reflecting the recent OECD BEPS discussions. It remains to be seen how these rules will stand their test in the future.  

It is expected that – also in conjunction with the ongoing negotiations of a fair-trade-agreement between Japan and the EU – the new DTT will stimulate the economic relationships between Germany and Japan.