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This article aims to assess the flexibility of Japanese tax treaties regarding non-discrimination clauses in corporate reorganizations.

April 1, 2026Open Access

Cross-border Corporate Reorganizations and Non-discrimination Clauses : Focusing on Two Protocols in Japanese Tax Treaties

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Analysis of tax treaty policies shows implications for corporate reorganizations in Japan, indicating areas for improvement.

This article aims to assess the flexibility of Japanese tax treaties regarding non-discrimination clauses in corporate reorganizations.
Review of current Japanese tax treaty conclusion policy.
Analysis of non-discrimination clauses in two specific protocols.
Evaluation based on the OECD Model and scholarly work.
Current non-discrimination clauses do not support preferential tax treatments for corporate reorganizations.
Some states' negotiation practices favor including corporate reorganizations in relief discussions.
Japanese tax treaty policy aligns with OECD Model standards, suggesting reference options for other countries.

Shigetaka Nakamura (2023) studied this question.

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