Treaty detail
Japan - Taiwan tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2015-11-26
Effective
2017-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 10%
The Japan-Taiwan arrangement (formally a private-sector agreement between the Interchange Association in Tokyo and the Association of East Asian Relations in Taipei, given effect by domestic implementing legislation) generally applies a uniform cap on cross-border dividends. The precise outcome still depends on beneficial ownership.
Interest
Rate: 10%
Government-related interest and qualifying central-bank interest may be exempt. The general 10 percent cap applies subject to beneficial ownership.
Royalties
Rate: 10%
Royalty treatment under this arrangement caps the source-country rate at 10 percent for most categories, including industrial, commercial, and scientific equipment use.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent rules apply where a person habitually concludes contracts on behalf of the enterprise. Independent agents acting in the ordinary course of business are generally excluded.
Other treaty flags
Pension taxation is generally allocated to the residence state under this arrangement, with separate rules for government-service pensions.
Seeded article summaries
Article 4
Residence
Defines residence and is the gateway to any benefit under the arrangement.
Because the Japan-Taiwan instrument is technically a private-sector arrangement given effect domestically, residence analysis still maps to domestic-law residence under each jurisdiction's implementing legislation.
Article 5
Permanent Establishment
Sets the business-presence threshold for cross-border activity.
Article 5 follows the OECD-influenced model with a 12-month construction-site threshold and a services threshold. The combination tends to be relevant for engineering and consulting services flowing between Japan and Taiwan.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment in the other state.
Once PE is ruled out under Article 5, Article 7 generally restricts taxation of Japanese-residents' business profits to Japan and Taiwan-residents' to Taiwan.
Article 10
Dividends
Provides the treaty cap on cross-border dividend withholding.
Article 10 generally produces a uniform treaty cap regardless of the recipient's shareholding percentage. The arrangement does not include the parent-subsidiary differential that some Japanese treaties contain.
Article 11
Interest
Caps source-country withholding on cross-border interest with government-interest carve-outs.
Article 11 caps the general rate at 10 percent. Government-related interest may qualify for broader treaty exemptions.
Article 12
Royalties
Caps source-country withholding on royalties at a uniform rate.
The royalty article matters for Japanese manufacturers licensing technology to Taiwanese counterparties. The precise rate and definition should be confirmed against Article 12.
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
- TreatyGB–JP treaty
- TreatyCA–JP treaty
- TreatyAU–JP treaty
- TreatyDE–JP treaty
- TreatyFR–JP treaty
- TreatyJP–KR treaty
- TreatyCN–JP treaty
Primary sources
- Japan MOF tax conventions overviewVerified 2026-05-20
- Taiwan Ministry of Finance - tax treatiesVerified 2026-05-20
- OECD MLI signatories and partiesVerified 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.