New Tax Convention with Georgia was Signed

January 29, 2021

Ministry of Finance

[Provisional translation]

1. Today, the Government of Japan and the Government of Georgia signed 'Convention between Japan and Georgia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance' in Tbilisi.

2. This Convention wholly amends the existing Convention (Convention between the Government of Japan and the Government of the Union of Soviet Socialist Republics for the Avoidance of Double Taxation with respect to Taxes on Income), which entered into force in 1986, by expanding the extent of reduction of taxation on investment income, introducing measures for prevention of abuse of this Convention and assistance in the collection of tax claims, and reinforcing the exchange of information concerning tax matters. It is expected that, while eliminating double taxation and preventing international tax evasion and tax avoidance, this Convention promotes further mutual investments and economic exchanges between the two countries.
* This Convention will not affect the application of the existing Convention between Japan and the countries other than Georgia.

【Reference 1】 Next Steps
After the approval in accordance with the domestic procedures of the two countries (in Japan, approval by the Diet is necessary), this Convention will enter into force on the thirtieth day after the date of exchange of diplomatic notes indicating such approval and will have effect:

(a) in Japan:
(i) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or
after January 1 in the calendar year next following that in which this Convention enters into force; and

(ii) with with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1 in the
calendar year next following that in which this Convention enters into force; and

(b) in Georgia:
(i) with respect to taxes withheld at source, to income derived on or after January 1 in the calendar year next
following that in which this Convention enters into force; and

(ii) with respect to other taxes, for taxes chargeable for any taxable year beginning on or after January 1 in the
calendar year next following that in which this Convention enters into force.

The provisions concerning the exchange of information and the assistance in the collection of taxes will have effect from the date of entry into force of this Convention without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.

【Reference 2】 Texts and Key Points of the Convention

・'Convention between Japan and Georgia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance'（Japanese(PDF:224KB) ・English(PDF:72KB)）

・Key Points of New Tax Convention with Georgia