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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Double Taxation Relief Manual: Guidance by country: Japan: Persons entitled to the benefits of the treaty

Under Article 1, the treaty applies to persons who are resident in Japan or the United Kingdom.

But those residents can only obtain the benefits provided by the treaty if they are a qualified person under one of the criteria set out in Article 22.