India’s Ministry of Finance has confirmed that the MoU with Japan on tax collection assistance will apply to requests submitted on or after 8 July 2025, following India’s signature date.
India’s Ministry of Finance has confirmed that the Memorandum of Understanding (MoU) with Japan on assistance in the collection of taxes will apply to any request submitted on or after 8 July 2025.
The MoU, signed in Tokyo on 30 June 2025 and in New Delhi on 8 July 2025, operates under Article 26A of the India–Japan Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Paragraph 21 of the MoU specifies that its provisions apply to requests for tax collection made after the later of the dates of signature by the two competent authorities. As the Indian signature date is the later, 8 July 2025 marks the effective date in India.
Under sub-section (1) of section 90 of the Income-tax Act, 1961, the Central Government has directed that all provisions of the MoU, as outlined in the notification’s annexure, shall be enforced within India.
