in Japan. (i) the income tax;
in Japan. (i) the taxes referred to in clauses (i) to (iv) of subparagraph (b) of paragraph 3 of Article 2;
in Japan. (i) with respect to taxes withheld at source, for amounts taxable on or after January 1 of the calendar year next following the expiration of the six month period; and
in Japan. (i) with respect to 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 Convention enters into force;
in Japan. (i) with respect to taxes withheld at source, for amounts taxable on or after 1st January in the calendar year next following that in which the Convention enters into force; and
in Japan. (i) with respect to taxes withheld at source, for amounts taxable on or after the first day of January of the calendar year next following that in which this Agreement enters into force;
in Japan. The income tax and the corporation tax (hereinafter referred to as “Japanese tax”); and the local taxes referred to in Articles V and XVII of the present Convention.
in Japan as respects income for any taxable year beginning on or after the first day of January in the calendar year in which the exchange of the instruments of ratification takes place.
in Japan. DRAMs (Korea), the Panel found that countervailing duties may only be imposed to offset present subsidization. In that case, Japan's investigating authority had found that a benefit was conferred by a subsidy provided in 2001, had allocated the benefit conferred by the 2001 subsidy over a period of five years only, and had imposed a countervailing duty in 2006 (i.e., after the relevant period of benefit allocation had expired). The Panel explained that the obligation to demonstrate present subsidization at the time of duty imposition was not inconsistent with the practice of investigating authorities establishing the existence of subsidization on the basis of past periods of investigation: "The obligation to establish present subsidization does not mean that investigating authorities are prevented from establishing the existence of subsidization (and injury and causing) by reference to data taken from a past period of investigation. To the contrary, given the need for investigating authorities to issue questionnaires, collect reliable and verifiable data, process and verify that data, and safeguard the due process rights of interested parties, investigating authorities have no choice but to establish the existence of subsidization (and injury) on the basis of past periods of investigation. Thus, countervailing duties may be imposed on the basis of the investigating authority's review of a past period of investigation. We are not suggesting that an investigating authority is somehow required to conduct a new investigation at the time of imposition, in order to confirm the continued existence of the subsidization found to exist during the period of investigation. That would defeat the very purpose of using periods of investigation in the first place. However, the use of a past period of investigation does not negate the need for an investigating authority to be satisfied that there is present subsidization. Rather, the historical data from the period of investigation 'is being used to draw conclusions about the current situation,' '[b]ecause the conditions to impose [a duty] are to be assessed with respect to the current situation'. In this sense, the situation during the period of investigation is used as a proxy for the situation pertaining 'current[ly]', at the time of imposition. In the case of non-recurring subsidies, if the review of the period of investigation indicates that the subsidy will no longer exist at the time of imposition, the existence of ...
in Japan as regards income for any taxable year beginning on or after the first day of January of the calendar year next following that in which the notice of termination is given.
