Japan, Austria Agree MAP Arbitration

The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries.

The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes.

The new agreement will also reduce the withholding tax rate at source on investment income (dividends, interest, and royalties), and expand cooperation between the tax authorities of the two countries by providing for assistance in the collection of taxes.

The Organisation for Economic Co-operation and Development in its Final Report on base erosion and profit shifting (BEPS) Action 14 recommended countries to adopt binding mandatory MAP arbitration to arbitrationmake dispute resolution mechanisms more effective. Japan and Austria are among the 20 countries that declared their commitment under the BEPS project to provide for mandatory binding MAP arbitration in their bilateral tax treaties.

The changes to the agreement will come into force after the completion of the approval process in both countries.