in Japan. (i) the taxes referred to in clauses (i) to (iv) of subparagraph (b) of paragraph 3 of Article 2;
(ii) the special corporation tax for reconstruction;
(iii) the consumption tax;
(iv) the local consumption tax;
(v) the inheritance tax; and
(vi) the gift tax;
in Japan. (i) the income tax;
(ii) the corporation tax;
(iii) the special income tax for reconstruction;
(iv) the local corporation tax; and
(v) the local inhabitant taxes (hereinafter referred to as “Japanese tax”).
in Japan. (i) with respect to taxes withheld at source, for amounts taxable on or after January 1 of the calendar year next following the expiration of the six month period; and
(ii) 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 January 1 of the calendar year next following the expiration of the six month period; and
in Japan. (i) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after 1 January in the calendar year next following that in which the Convention enters into force;
(ii) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after 1 January in the calendar year next following that in which the Convention enters into force.
in Japan. (i) with respect to taxes withheld at source, for amounts taxable on or after 1st January of the calendar year next following that in which the Convention enters into force; and
(ii) 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 of the calendar year next following that in which the Convention enters into force; and
in Japan as regards income for any taxable year beginning on or after the first day of January of the calendar year next following that in which in notice of termination is given; and
in Japan. (i) with respect to taxes withheld at source, for amounts taxable on or after the first day of January of the calendar year next following that in which this Agreement enters into force;
(ii) 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 the first day of January of the calendar year next following that in which this Agreement enters into force.
in Japan. DRAMs (Korea), the Panel found that countervailing duties may only be imposed to offset present subsidization. In that case, Japan's investigating authority had found that a benefit was conferred by a subsidy provided in 2001, had allocated the benefit conferred by the 2001 subsidy over a period of five years only, and had imposed a countervailing duty in 2006 (i.e., after the relevant period of benefit allocation had expired). The Panel explained that the obligation to demonstrate present subsidization at the time of duty imposition was not inconsistent with the practice of investigating authorities establishing the existence of subsidization on the basis of past periods of investigation: "The obligation to establish present subsidization does not mean that investigating authorities are prevented from establishing the existence of subsidization (and injury and causing) by reference to data taken from a past period of investigation. To the contrary, given the need for investigating authorities to issue questionnaires, collect reliable and verifiable data, process and verify that data, and safeguard the due process rights of interested parties, investigating authorities have no choice but to establish the existence of subsidization (and injury) on the basis of past periods of investigation. Thus, countervailing duties may be imposed on the basis of the investigating authority's review of a past period of investigation. We are not suggesting that an investigating authority is somehow required to conduct a new investigation at the time of imposition, in order to confirm the continued existence of the subsidization found to exist during the period of investigation. That would defeat the very purpose of using periods of investigation in the first place. However, the use of a past period of investigation does not negate the need for an investigating authority to be satisfied that there is present subsidization. Rather, the historical data from the period of investigation 'is being used to draw conclusions about the current situation,' '[b]ecause the conditions to impose [a duty] are to be assessed with respect to the current situation'. In this sense, the situation during the period of investigation is used as a proxy for the situation pertaining 'current[ly]', at the time of imposition. In the case of non-recurring subsidies, if the review of the period of investigation indicates that the subsidy will no longer exist at the time of imposition, the existence of ...
in Japan. (i) 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
(ii) 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. IN WITNESS WHEREOF the undersigned, being duly authorised thereto by their respective Governments, have signed this Convention. DONE in duplicate at London this second day of February, 2006, in the Japanese and English languages, each text being equally authoritative. For Japan: For the United Kingdom of Great Britain and Northern Ireland: Xxxxxxx Xxxxxx Xxxx Xxxxxxxxx At the signing of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains (hereinafter referred to as “the Convention”), Japan and the United Kingdom of Great Britain and Northern Ireland have agreed upon the following provisions, which shall form an integral part of the Convention.
1. With reference to subparagraph (m) of paragraph 1 of Article 3 of the Convention: A pension fund or pension scheme shall be treated as exempt from tax on income derived with respect to the activities described in clause (ii) of that subparagraph even though it is subject to the tax stipulated in Articles 8 or 10-3 of the Corporation Tax Law (Law No. 34 of 1965) of Japan or paragraph 1 of Article 20 of its supplementary provisions.
2. With reference to Article 7
in Japan. The income tax and the corporation tax (hereinafter referred to as “Japanese tax”); and the local taxes referred to in Articles V and XVII of the present Convention.
