Japan's Ministry of Finance has announced an exchange of notes with Denmark regarding the effective date of the arbitration provisions in the 2017 income tax treaty between the two countries. Based on the exchange of notes, the arbitration provisions in paragraph 5 of Article 24 (Mutual Agreement Procedure) of the treaty shall have effect:

• with respect to cases presented pursuant to paragraph 1 of that Article on or after 5 November 2021; and
• with respect to cases presented pursuant to paragraph 1 of that Article before 5 November 2021, although in this case, no unresolved issues of such case shall be submitted to arbitration before two years have elapsed from 5 November 2021.

Click the following link for the English text of the exchange of notes.