New Zealand and Japan have signed a new double taxation agreement that will replace the existing 1963 treaty, as announced today by Finance Minister Peter Dunne. "Japan is one of New Zealand`s major trading partners and the current treaty is our oldest tax information exchange agreement. The updated agreement recognizes the volume of trade between our two nations and the importance of our relationship with Japan. In order to avoid duplication of registration in the social security sector, Japan has entered into social security agreements with several countries. The current agreements with Australia, Belgium, Brazil, Canada, China, the Czech Republic, France, Germany, Hungary, India, Ireland, Korea, Luxembourg, the Netherlands, the Philippines, the Slovak Republic, Spain, Switzerland, the United Kingdom and the United States of America are applicable on June 30, 2020. Agreements with Finland, Italy and Sweden have been signed and are in the process of being implemented. (a) the competent authorities agree to establish a procedure to ensure that an arbitration decision will be complete within two years of an application for arbitration within the meaning of Article 26, paragraph 5 of the Convention, unless the actions or inaction of a person directly affected by the case submitted under this paragraph interfere with the decision of the case or unless the competent authorities and that person otherwise agree. The text of the new double taxation agreement is at taxpolicy.govt.nz/tax-treaties` Article 13, paragraph 6, of Article 13, paragraph 6, of the SBA, in order to avoid double taxation of capital gains on outgoing residents. Under the Australian CGT scheme, a person who no longer has a home in Australia is normally taxed on unrealized profits of CGT assets held on that date, with assets other than taxable assets. However, a person who ceases to have an Australian-based tax may choose, at the time of departure, to either pay taxes (based on the difference between the market value of the non-taxable Australian assets at the time of departure and the cost base of those assets), or to defer tax on a possible profit until the effective disposal of these non-taxable Australian assets. In both cases, this person is treated as if he had disposed of tax-free Australian assets and acquired it at fair value if, under New Zealand tax law (which currently does not impose capital gains), he is no longer resident in Australia. Reducing withholding tax on interest, dividend and royalty payments between the two countries will be a key feature of the updated agreement, making it less costly for companies to invest in any country and bring back profits for reinvestment or distribution to shareholders. The updated agreement was signed last night in Tokyo, New Zealand by Japan`s Deputy Parliamentary Foreign Minister Kazuya Shimba and New Zealand`s Ambassador to Japan, Mark Sinclair.
The updated agreement with Japan will enter into force as soon as both countries have conferred legal effects on it. In New Zealand, this will be done through a Council Medal.