Article 1 - Personal Scope - Japan

MINISTRY OF FINANCE (Department of Revenue) (Foreign Tax Division) NOTIFICATION New Delhi, the 1st March, 1990 INCOME-TAX AS AMENDED VIDE NOTI. NO. SO 1136(E), DT. 19-7-2006, W.R.E.F. 28-6-2006 G.S.R. 101(E). WHEREAS the annexed Convention between the Government of the Republic of India and the Government of Japan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income has come into force on the 29th December, 1989, after the exchange of instruments of ratification as required by Paragraph 1 of article 28 of the said Convention; NOW, THEREFORE, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said Convention shall be given effect to in the Union of India. ANNEXURE Convention between the Government of Japan and the Government of the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income The Government of Japan and the Government of the Republic of India, desiring to conclude a new Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, Have agreed as follows : Article 1 This Convention shall apply to persons who are residents of one or both of the Contracting States.