On 5 November 2021, the Japanese Ministry of Finance announced an exchange of notes with Denmark regarding the entry into force of the arbitration provisions in the 2017 income tax treaty between the two countries. Due to the exchange of notes, the arbitration provisions of Article 24 paragraph 5 (agreement procedure) of the contract apply:
- With respect to cases presented pursuant to paragraph 1 of that Article on or after 5 November 2021; and
- With respect to cases presented pursuant to paragraph 1 of that Article before 5 November 2021, although in this case, no unresolved issues of such case shall be submitted to arbitration before two years have elapsed from 5 November 2021.
