For the purposes of [this Convention], income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either [Contracting State] shall be considered to be income of a resident of a [Contracting State] but only to the extent that the income is treated, for purposes of taxation by that [Contracting State], as the income of a resident of that [Contracting State]. In no case shall the provisions of this paragraph be construed to affect a [Contracting State’s] right to tax the residents of that [Contracting State].
Citation to select or copy
United Kingdom / Japan; HMRC, Synthesised text of the Multilateral Instrument and the 2006 UK-Japan Double Taxation Convention; edition Official MLI synthesis of 2006 Convention as amended by 2013 Protocol; HMRC updated 13 November 2018; article 1; English; source role publisher-synthesis; Official publisher synthesis, not an authentic signed original or current-law certification. Publisher qualifications remain source text and searchable.; unreviewed source text, current applicability unverified; /editions/gb-jp-2006-hmrc-mli-synthesis-html-reserve-v1/en/articles/article-1/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
Source & edition
HMRC, Synthesised text of the Multilateral Instrument and the 2006 UK-Japan Double Taxation Convention
Digest scope: retained online-source capture; no PDF binary verification
Publisher role and language
Official publisher synthesis, not an authentic signed original or current-law certification. Publisher qualifications remain source text and searchable.
Official publisher synthesis, not assistant consolidation; differentiated MLI effects and precedence of authentic texts retained verbatim.
Actual supplied body languages: English. A language named by an instrument is not a supplied translation.
Edition
Official MLI synthesis of 2006 Convention as amended by 2013 Protocol; HMRC updated 13 November 2018
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Underlying instrument signature
2006-02-02
Languages recorded in source metadata: English. This is not a promise of available text or a translation.
Edition notes and known limitations
Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.
Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.
Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.
Original source headings provide Article numbers without subject titles; no editorial titles fabricated. Only English publication body captured; Japanese authentic text not supplied in this manifestation.
Publisher synthesis, not an authentic treaty instrument. MLI replacement text and explanations are retained; original boxes/layout are not reproduced. Authentic Convention and MLI texts take precedence.
Source authority, text completeness and currentness still require human review.