The form is prepared for each payer. It is submitted to the head of the tax office through the payer, no later than the day before the recipient first receives the income1.

Consider a hypothetical example of a payment of 10 million yen with a domestic-law rate of 20% and a treaty maximum rate of 10%. If the form is filed in time, 1 million yen is withheld. If it is not, 2 million yen is withheld. In that case, the recipient can later file a refund claim form and claim the 1 million yen difference2. The reconstruction special income tax is not included.

Which article of which treaty applies to a derivative payment depends on the treaty and on what the payment is.

Notes

  1. National Tax Agency, "No.2888 租税条約に関する届出書の提出（源泉徴収関係）" (Submission of application forms for income tax conventions (withholding)) (laws and regulations as of April 1, 2026), "概要" (Overview), "共通事項" (Common matters) (in Japanese). ↩

  2. National Tax Agency, "No.2889 租税条約に関する源泉徴収税額の還付請求" (Refund claims for withholding tax under income tax conventions) (laws and regulations as of April 1, 2026), "概要" (Overview) (in Japanese). ↩