The compatibility of the UTPR and Japan´s tax treaties Takato Masuda
By: Masuda, Takato
.
Material type: 
ArticlePublisher: 2024Subject(s): UTPR (OCDE) | IMPUESTOS | JAPON
In:
Tax Notes International v. 114, n. 8, May 20 2024; p. 1127-1145.Summary: Takato Masuda is an associate at Nishimura & Asahi in Tokyo. He thanks Mitchell Kane for his invaluable support throughout the writing process.
This article earned the International Fiscal Association USA Branch Writing Prize Award at the 52nd annual meeting in March 2024. It is based on the author’s research paper for the LLM International Tax Program at New York University during the 2023 academic year, which was awarded the David F. Bradford Memorial Prize for the best tax paper of the year. In this article, Masuda examines and rebuts criticism of the UTPR (formerly known as the undertaxed payments rule) in light of tax treaties, and considers how the UTPR might fare under relevant Japanese case law.
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Takato Masuda is an associate at Nishimura & Asahi in Tokyo. He thanks Mitchell Kane for his invaluable support throughout the writing process.
This article earned the International Fiscal Association USA Branch Writing Prize Award at the 52nd annual meeting in March 2024. It is based on the author’s research paper for the LLM International Tax Program at New York University during the 2023 academic year, which was awarded the David F. Bradford Memorial Prize for the best tax paper of the year. In this article, Masuda examines and rebuts criticism of the UTPR (formerly known as the undertaxed payments rule) in light of tax treaties, and considers how the UTPR might fare under relevant Japanese case law.
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