On December 19, 2025, officials from Japan and the Kyrgyz Republic signed a tax treaty in Tokyo.
The tax treaty wholly amends the existing tax treaty, which entered into force in 1986.
The new tax treaty contains dividend withholding tax rate of five percent in cases of substantial shareholding (and ten percent in other cases), and an interest and royalty withholding tax rate of eight percent.
A principal purpose test is inserted in the tax treaty. The tax treaty also includes provisions on mutual agreement procedure and exchange of information.
The text of the tax treaty is available on the website of the Ministry of Finance, Japan.
