2019 Japan-Uruguay Income Tax Treaty Available

<p>Tax Analysts has obtained the English text of the Japan-Uruguay income tax treaty signed September 13 in Montevideo.</p> <p>Under the treaty, dividends are taxable at a maximum rate of 5 percent if the beneficial owner is a company that directly owns, throughout a 183-day period that includes the date on which entitlement to the dividends is determined, at least 10 percent of:</p> <ul> <li>where the payer company is a resident of Japan, the voting power of that company; or</li> <li>where the payer company is a resident of Uruguay, the capital of that company.</li> </ul> <p>A 10 percent rate applies to dividends in other cases. Interest and royalties are taxable at a top rate of 10 percent. However, interest is taxable only in the recipient's state of residence if:</p> <ul> <li>the interest is beneficially owned by that state, a political subdivision or local authority thereof, the central bank or any institution wholly owned by that state or a political subdivision or local authority thereof;</li> <li>the interest is beneficially owned by a resident of that state with respect to debt-claims guaranteed, insured or indirectly financed by that state, a political subdivision or local authority thereof, the central bank or any institution wholly owned by that state or a political subdivision or local authority thereof;</li> <li>the interest is beneficially owned by a financial institution that is a resident of that state and the interest is paid:  <ul> <li>by a financial institution that is a resident of the source state; or</li> <li>in respect of debt-claims granted for a period of at least three years for the financing of investment projects.</li> </ul> </li> </ul> <p>Both countries generally apply the credit method to eliminate double taxation. </p> <p>This is the first income tax treaty between Japan and Uruguay. It will enter into force on the thirtieth day following the exchange of ratification instruments and its provisions will generally apply from January 1 of the year following entry into force. The provisions on exchange of information and assistance in the collection of taxes will apply from the date of entry into force without regard to the date on which the taxes are levied or the tax year to which the taxes relates.</p> 

<p><a href="/lr/resolve/-/29yr3" title=" ">Japanese text</a>. <a href="/lr/resolve/-/29ysr" title=" ">Japanese Ministry of Finance release</a>. <a href="/lr/resolve/-/29ysq" title=" ">Key points of treaty</a>. <a href="/lr/resolve/-/29ybk" title=" ">Prior coverage</a>.</p>

<p>July 23, 2021 (exchange of information and assistance in the collection of taxes); January 1, 2022 (withholding and other taxes). See Article 29.</p>

<p>Tax Analysts has obtained the English text of the Japan-Uruguay income tax treaty signed September 13 in Montevideo.</p>

Tax Analysts has obtained the English text of the Japan-Uruguay income tax treaty signed September 13 in Montevideo. Under the treaty, dividends are taxable at a maximum rate of 5 percent if the beneficial owner is a company that directly owns, throughout a 183-day period that includes the date on which entitlement to the dividends is determined, at least 10 percent of: where the payer company is a resident of Japan, the voting power of that company; or where the payer company is a resident of Uruguay, the capital of that company. A 10 percent rate applies to dividends in other cases. Interest and royalties are taxable at a top rate of 10 percent. However, interest is taxable only in the recipient's state of residence if: the interest is beneficially owned by that state, a political subdivision or local authority thereof, the central bank or any institution wholly owned by that state or a political subdivision or local authority thereof; the interest is beneficially owned by a resident of that state with respect to debt-claims guaranteed, insured or indirectly financed by that state, a political subdivision or local authority thereof, the central bank or any institution wholly owned by that state or a political subdivision or local authority thereof; the interest is beneficially owned by a financial institution that is a resident of that state and the interest is paid:  by a financial institution that is a resident of the source state; or in respect of debt-claims granted for a period of at least three years for the financing of investment projects. Both countries generally apply the credit method to eliminate double taxation.  This is the first income tax treaty between Japan and Uruguay. It will enter into force on the thirtieth day following the exchange of ratification instruments and its provisions will generally apply from January 1 of the year following entry into force. The provisions on exchange of information and assistance in the collection of taxes will apply from the date of entry into force without regard to the date on which the taxes are levied or the tax year to which the taxes relates.

<h4>Rate Table Instructions</h4> <ul> <li>You must enter a rate for each rate type</li> <li>Enter only one rate value per row</li> <li>You may leave the country columns blank if the rate is the same for both countries</li> <li>Country names (if entered) must exactly match the jurisdictions</li> <li>Leave the Partner Country column blank if you want the rate to apply to all partners of the Main Country</li> <li>Enter "n/a" in each rate row to hide the partner in the Main Country table</li> <li>Note that the same rates may apply for Main Country and Partner Country or the Main Country may apply different rates to the Partner Country</li> </ul> <table> <tbody> <tr><th> <div>Rate Type</div> (Dividends, Interest, Royalties)</th><th>Main Country</th><th>Partner Country</th><th>Rate</th><th>Footnote 1</th><th>Footnote 2</th><th>Footnote 3</th><th>Footnote 4</th></tr> <tr> <td>Dividends</td> <td> </td> <td> </td> <td>5/10 </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Interest</td> <td> </td> <td> </td> <td>0/10 </td> <td>The 0 percent rate applies to interest beneficially owned by a financial institution where the interest is paid: by a financial institution that is a resident of the source state; or in respect of debt-claims granted for a minimum 3-year period for the financing of investment projects. The 10 percent rate applies in other cases. </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Royalties</td> <td> </td> <td> </td> <td>10 </td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

Japan - Uruguay: 2019 Income Tax Convention and Final Protocol

Japan

Search Connectors

Retrieving Documents With a Tax Analysts’ Citation:

Field Restricted Searching:

2019 Japan-Uruguay Income Tax Treaty Available