Japan's new income tax treaty with Kyrgyzstan will enter into force on 26 July 2026, replacing the 1986 agreement and introducing updated withholding tax rates, with most provisions applying from 1 January 2027.
Japan’s Ministry of Foreign Affairs has announced that the new income tax treaty with Kyrgyzstan will enter into force on 26 July 2026.
Signed on 19 December 2025, the treaty replaces the 1986 tax treaty between Japan and the former Soviet Union in its application to Japan and Kyrgyzstan.
The treaty applies to Kyrgyz tax on profits of legal persons and income tax on individuals. On the Japanese side, it covers income tax, corporation tax, special income tax for reconstruction, local corporation tax, special corporation tax for defence, and local inhabitant taxes.
The treaty sets a maximum withholding tax rate of 5% on dividends where the beneficial owner is a company holding at least 10% of the paying company’s voting power or capital for a continuous six-month period, and 10% in all other cases. Interest and royalties are subject to an 8% withholding tax rate, with interest exempt in certain cases, including payments to governments, central banks, state-owned institutions, government-backed debt claims, and qualifying credit arrangements for the sale of equipment, merchandise, or services.
The new treaty generally takes effect from 1 January 2027, while its provisions concerning the exchange of information apply from the date on which the treaty enters into force.
