ARTICLE 11

U.S. Income Tax Treaty — Japan Technical Explanation - 1971 · 2026-10-03 edition · updated 2026-10-04 · United States

Related Persons

This article complements section 482 of the Internal Revenue Code and confirms the power of each government under its internal laws to allocate items of income, deduction, credit, or allowance in cases in which a resident of one State is related to any other person if such related persons impose conditions between themselves which are different from conditions which would be imposed between independent persons. A similar provision was included in the 1954 Convention and in the OECD Model Convention.

Provision is made in Article 25 (relating to mutual agreement procedures) for consultation and agreement between the two States where an allocation by either State results or would result in double taxation.

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▸Contents — U.S. Income Tax Treaty — Japan Technical Explanation - 1971

U.S. Income Tax Treaty — Japan Technical Explanation - 1971

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