Briefwisseling houdende een Verdrag tot wijziging van het Verdrag tussen het Koninkrijk der Nederlanden en Japan tot het vermijden van dubbele belasting en het voorkomen van het ontgaan van belasting met betrekking tot belastingen naar het inkomen, Tokio, 06-08-2012

MINISTRY OF FOREIGN AFFAIRS OF JAPAN
Tokyo, August 6, 2012
Madam,
I have the honour to refer to the Convention between Japan and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at Tokyo on 25 August 2010 (hereinafter referred to as “the Convention”) as well as the Protocol which forms an integral part of the Convention signed at Tokyo on 25 August 2010 (hereinafter referred to as “the Protocol”) and to confirm, on behalf of the Government of Japan, the following understanding reached between the two Governments:
With reference to paragraph 6 of the Protocol, it is agreed upon that the Japan Bank for International Cooperation shall be regarded as an institution as referred to in paragraph 6a) (v) of the Protocol.
If the foregoing understanding is acceptable to the Government of the Netherlands, I have the honour to propose that the present Note and your Note in reply to that effect should be regarded as constituting an arrangement between the two Governments in this matter, which shall enter into force on the date of your Note in reply and shall be applicable in retroactive for amounts taxable on or after the first day of April, 2012.
I avail myself of this opportunity to extend to you the assurance of my high consideration.
KOICHIRO GEMBA
Minister for Foreign Affairs of Japan
Ms. Catharina Maria Trooster
Chargé d’Affaires ad interim
Embassy of the Kingdom
of the Netherlands to Japan

EMBASSY OF THE KINGDOM OF THE NETHERLANDS
Tokyo, 6 August 2012
Excellency,
I have the honour to acknowledge the receipt of Your Excellency’s Note of today’s date which reads as follows:
[Red: (Zoals in Nr. I)]
The foregoing understanding being acceptable to the Government of the Netherlands, I have the honour to confirm that Your Excellency’s Note and this Note in reply shall be regarded as constituting an arrangement between the two Governments in this matter, which shall enter into force on the date of this Note in reply and shall be applicable in retroactive for amounts taxable on or after the first day of April, 2012.
I avail myself of this opportunity to extend to Your Excellency the assurance of my highest consideration.
CATHARINA MARIA TROOSTER
Chargé d’Affaires ad interim
Embassy of the Kingdom of the
Netherlands to Japan
His Excellency
Mr Koichiro Gemba
Minister for Foreign Affairs of Japan