Treaty detail
Canada - Japan tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1986-05-07
Effective
1987-11-14
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold under the treaty as amended by the 1999 protocol.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government, central-bank, and certain pension-fund interest under the article.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling across the core categories.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the OECD model wording as adapted in the treaty.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence as amended by the 1999 protocol.
Article 4 reflects the protocol-amended wording. Residence analysis interacts with Canada's mind-and-management approach and Japan's incorporation-based residence rules.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The treaty uses the standard 12-month construction-site threshold as amended.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 has been refined by protocol to reflect OECD-aligned profit-attribution principles.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 15 percent and 5 percent treaty ceilings as amended by the 1999 protocol.
Article 11
Interest
Limits source-country withholding on qualifying interest.
Article 11 produces a 10 percent ceiling with carve-outs for qualifying government and pension-fund interest.
Article 12
Royalties
Caps royalties at a 10 percent ceiling.
Article 12 generally limits royalties to 10 percent across the core categories.
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–CA treaty
- TreatyUS–JP treaty
- TreatyGB–CA treaty
- TreatyGB–JP treaty
- TreatyCA–MX treaty
- TreatyAU–CA treaty
- TreatyCA–DE treaty
- TreatyCA–FR treaty
Primary sources
- Canada Department of Finance: 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.