who are interested in opening a company in Germany
or to get involved in trading activities with this country can benefit from the provisions of the double taxation agreement (DTA)
signed by the two states. It is important to know that Germany and Japan
signed an updated version of the treaty
, which should become effective starting with 1st of January 2017. Our team of German attorneys
can provide an in-depth presentation on the taxes
covered by the agreement
and on the main changes established by the two parties.
Short history of the Germany – Japan DTA
Germany and Japan
first signed a treaty for the avoidance of double taxation
applicable to natural persons and legal entities, tax residents
of the two states, in 1967. The treaty
was modified in 1979, and later on, in 1983. Due to the fact that the provisions of the agreement
became outdated, the Japanese and German authorities
have recently made a new amendment, which will improve the benefits of the current document; our team of German lawyers
can offer more details in this sense.
The new DTA between Germany and Japan
who want to set up a company in Germany
should know that the new provisions of the treaty
will provide more benefits than the current DTA
, as several taxes
have been lowered. The representatives of the two states signed the revised version of the treaty on the 17th of December 2015, introducing new regulations that reflect the current legal view of the Organisation for Economic Cooperation and Development (OECD).
One of the main aspects refers to the elimination (or reduction) of the withholding taxes, applicable to dividends, royalties and interests. The withholding tax on royalties and interest are no longer applicable, while the withholding tax on dividends will be imposed as follows:
• 0% if the shareholder owns 25% of the voting rights for a period longer than 18 months;
• 5% if the shareholders owns 10% of the voting rights for minimum 6 months;
• a rate of 15% is applicable in other situations.
Businessmen who are interested in receiving more details on the new double taxation treaty
signed by Germany and Japan
can address to our German law firm
for legal assistance.