The agreement details the procedures for the arbitration of their 2015 tax treaty between the two countries.
The German Ministry of Finance released an agreement on 4 June 2025, signed with Japan, detailing the application of arbitration procedures under paragraph 5 of Article 24 (Mutual Agreement Procedure) of the 2015 tax treaty between the two countries.
The agreement applies to all arbitration requests submitted on or after 1 January 2017.
Under paragraph 5, if a case remains unresolved for more than two years, the unresolved issues must be submitted to arbitration upon request by the affected person. The agreement outlines procedures for initiating arbitration, the selection and appointment of arbitrators, the conduct of the arbitration, and the implementation of final decisions.