Further to the July-August 2019 issue of this newsletter, the protocol to amend the U.S.–Japan Tax Treaty ("Protocol") entered into force upon the exchange of ratification instruments between Japan and the United States on August 30, 2019, in Tokyo. The Protocol will apply to: (i) taxes withheld for amounts paid on or after November 1, 2019; and (ii) other taxes for taxable years beginning on or after January 1, 2020. Benefits available under the treaty will be increased by the Protocol, including a broadening of the tax exemption on dividends (i.e., the required share-holding ratio is changed from "more than 50 percent" to "at least 50 percent," and the required holding period is shortened to "six months" from the current "twelve months") as well as an exemption from withholding taxes on interest payments.
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