Treaty detail
Australia - Japan tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2008-01-31
Effective
2008-12-03
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 0%
The treaty provides zero treatment for qualifying corporate shareholders with substantial direct ownership. Portfolio dividends face the 10 percent ceiling.
Interest
Rate: 10%
The 10 percent ceiling can be reduced to zero for qualifying financial-institution and government interest under the article.
Royalties
Rate: 5%
The treaty caps royalties at 5 percent across the core categories under the modernized 2008 wording.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows modernized 2008 treaty wording.
Other treaty flags
Pension treatment is article-specific. The treaty's pension fund treatment is favorable for qualifying entities.
Seeded article summaries
Article 4
Residence
Defines treaty residence under modern OECD-aligned rules.
Article 4 reflects the modern OECD model. Dual-resident entity cases are resolved through mutual agreement procedure.
Article 5
Permanent Establishment
Sets the business-presence threshold including offshore-resource provisions.
The treaty uses the standard 12-month construction threshold and includes specific rules for offshore-resource activities relevant to both jurisdictions.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 follows the OECD's authorised-approach to profit attribution.
Article 10
Dividends
Caps source-country dividend withholding with a zero rate for qualifying substantial shareholders.
Article 10 provides zero treatment for qualifying corporate shareholders meeting the substantial-direct-ownership threshold. Portfolio dividends face the 10 percent ceiling.
Article 11
Interest
Limits source-country withholding on interest with carve-outs.
Article 11 produces a 10 percent ceiling but allows zero treatment for qualifying financial-institution and government interest.
Article 12
Royalties
Caps royalties at 5 percent under the modernized treaty.
Article 12 is favorable for software, licensing, and IP structures because the 5 percent ceiling materially reduces source-country withholding.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–JP treaty
- TreatyUS–AU treaty
- TreatyGB–AU treaty
- TreatyGB–JP treaty
- TreatyAU–CA treaty
- TreatyCA–JP treaty
- TreatyAU–SG treaty
- TreatyAU–IN treaty
Primary sources
- ATO: tax treatiesVerified 2026-05-20
- Japan MOF: tax conventionsVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.