ARTICLE 32
Termination
This Agreement shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year beginning after expiry of five years from the date of entry into force of the Agreement. In such event, the Agreement shall cease to have effect:
- (a) in the case of Japan:
- (i) in the case of taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after 1 January in the calendar year next following that in which the notice of termination is given; and
- (ii) in the case of taxes not levied on the basis of a taxable year, for taxes levied on or after 1 January in the calendar year next following that in which the notice of termination is given; and
- (b) in the case of the Federal Republic of Germany:
- (i) in the case of taxes withheld at source, in respect of amounts paid on or after 1 January in the calendar year next following that in which the notice of termination is given; and
- (ii) in the case of other taxes, in respect of taxes levied for periods beginning on or after 1 January in the calendar year next following that in which the notice of termination is given.
The notice of termination shall be regarded as having been given by a Contracting State on the date of receipt of such notice by the other Contracting State.
IN WITNESS WHEREOF, the undersigned, being duly authorised thereto, have signed this Agreement.
DONE at Tokyo, on this seventeenth day of December 2015, in two originals, each in the Japanese, German and English languages, all three texts being authentic. In the case there is any divergence of interpretation between the Japanese and the German texts, the English text shall prevail.
FOR JAPAN:
YOJI MUTO
FOR THE FEDERAL REPUBLIC OF GERMANY:
HANS CARL FREIHERR VON WERTHERN