Treaty detail
United Kingdom - Japan tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2006-02-02
Effective
2006-10-12
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 0%
The 2013 protocol provides zero treatment for qualifying corporate shareholders with substantial direct ownership and for pension funds. Portfolio dividends face the 10 percent ceiling under the article.
Interest
Rate: 10%
The 10 percent ceiling can be reduced to 0 percent for qualifying financial-institution, pension-fund, and government-related interest under the article.
Royalties
Rate: 0%
The treaty generally eliminates source-country withholding on qualifying royalties.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis updated by the 2013 protocol to reflect modernized OECD model 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 follows the modern OECD model. The 2013 protocol clarified several residence-tie-breaker provisions.
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. The 2013 protocol updated several dependent-agent provisions.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 aligns with the OECD's authorised-approach to profit attribution under the 2013 protocol.
Article 10
Dividends
Caps source-country dividend withholding, with a zero rate for qualifying substantial shareholders.
Under the 2013 protocol, qualifying corporate shareholders with substantial direct ownership can obtain a zero rate. The 10 percent ceiling applies otherwise.
Article 11
Interest
Limits interest withholding with zero treatment for qualifying recipients.
Article 11 produces a 10 percent general ceiling but allows zero treatment for qualifying financial-institution, pension-fund, and government-related interest.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding across the major categories under the article.
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–GB treaty
- TreatyUS–JP treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC: Japan 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.