Treaty detail
China - Japan tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1983-09-06
Effective
1984-06-26
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 10%
The older 1983 treaty applies a uniform 10 percent ceiling on dividends. China's domestic dividend-withholding rules apply where treaty conditions are not satisfied.
Interest
Rate: 10%
The treaty applies a 10 percent ceiling on most interest.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling under the older 1983 treaty.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the older 1983 wording includes specified habitual-conclusion rules.
Other treaty flags
Pension treatment is article-specific under the older 1983 treaty.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1983 wording.
Article 4 reflects the older 1983 treaty wording. Residence analysis interacts with China's Place-of-Effective-Management rules and Japan's residence-by-incorporation rules.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both construction and service-PE rules under the older 1983 wording.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services. The service-PE rule affects its protective effect.
Article 10
Dividends
Caps source-country dividend withholding at a uniform 10 percent ceiling.
Article 10 does not differentiate dividend rates by direct-ownership level.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 10 percent ceiling.
Article 11 produces a 10 percent ceiling with carve-outs for qualifying government and central-bank interest.
Article 12
Royalties
Caps royalties at a 10 percent ceiling.
Article 12 limits royalties at 10 percent under the older 1983 treaty.
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–CN treaty
- TreatyGB–JP treaty
- TreatyGB–CN treaty
- TreatyCA–JP treaty
- TreatyCA–CN treaty
- TreatyAU–JP treaty
- TreatyAU–CN treaty
Primary sources
- State Taxation Administration of ChinaVerified 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.