THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNION OF SOVIET SOCIALIST REPUBLICS AND THE GOVERNMENT OF JAPAN

of January 18, 1986

About avoidance of double taxation concerning taxes on the income

Government of the Union of Soviet Socialist Republics and Government of Japan,

wishing to sign the Convention on avoidance of double taxation concerning taxes on the income,

agreed about the following:

Article 1

1. This Convention is applied to persons who are persons with the permanent residence in one or in both Contracting States.

2. For the purposes of this Convention the term "person with the permanent residence in the Contracting State" means any person who is subject to the taxation in this Contracting State on the basis of residence, regular residence, the location of head office, the place of management or any other criterion of similar nature.

3. In case according to Item 2 provisions person is person with the permanent residence in both Contracting States, then competent authorities of Contracting States determine by mutual consent the Contracting State in which this person is considered person with the permanent residence for the purposes of this Convention.

Article 2

1. This Convention extends to the following taxes:

a) in Japan:

(i) income tax;

(ii) tax on corporations; and

(iii) the local taxes from the population;

b) in the Union of Soviet Socialist Republics (which is hereinafter referred to as by USSR):

(i) the income tax from the population; and

(ii) the income tax from foreign legal entities.

2. This Convention extends also to any identical or in essence similar taxes which are levied after signature date of this Convention in addition to about what it is told in Item 1, or instead of them.

Disclaimer! This text was translated by AI translator and is not a valid juridical document. No warranty. No claim. More info