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Japan–Vietnam tax treaty · exit tax

Japan’s domestic residence is domicile or one continuous year — not a 183-day myth. The exit-tax gate is ¥100 million of covered assets and more than five years in the prior ten. Treaty in force since 1995-12-31. MLI withholding from 2024-01-01.

Visa → days → tax → labour

  1. TRC / stay sets how long you may remain.
  2. Days and habitual abode decide Vietnam tax residence (threshold 183 days).
  3. Working needs a permit or exemption — separate from tax.
  4. Relief between the states runs through the Japan–Vietnam DTA (signed 1995-10-24).

Treaty article caps on file

Primary MOF synthesised MLI text. Article-by-article PPT / other overrides are not re-celled here.

Article / topicOn file
Dividends10 %
Interest10 %
Royalties10 %
Construction PEmore than 6 months
Services PEmore than 6 months within any twelve-month period
Art 15 short-stay limb183 days
Art 18 pensionsTaxable only in the residence state
Art 23 credit JP ← VN taxExists — dollar amounts refused
Art 23 credit VN ← JP taxExists — dollar amounts refused
MLI withholding effectFrom 2024-01-01
MLI other taxes — JapanPeriods from 2024-03-01
MLI other taxes — VietnamPeriods from 2025-01-01
Art 4 dual-resident tie-breakerpermanent home → centre of vital interests → habitual abode → nationality → mutual agreement

MLI applies to this pair. Article-by-article overrides beyond the WH effect date are not re-celled.

Dual residence — why day counts disagree

Japan-side traps

Domestic Japan gates. They do not travel from the Australia page. We state the gate — not the bill.

1. Worldwide tax for ordinary residents

Ordinary residents are taxed on whole income. A non-permanent resident category exists for certain non-Japanese nationals. Vietnam residence does not by itself switch worldwide tax off.

2. Domicile or one-year residence (not the 183-day myth)

Domestic tax residence uses domicile or continuous residence of 1 years. The treaty Art 15 short-stay limb uses 183 days — that is not Japan’s domestic residence test.

3. Exit tax

Leaving Japan permanently can trigger a deemed disposal of covered securities and unsettled derivatives when holdings total 100000000 JPY or more and domicile or residence exceeds 5 years in the prior 10 years. Regime from 2015-07-01. Payment deferral of 5 years (max 10 years) exists if a tax manager and collateral are filed before departure. Gain maths refused.

What stays refused

Dollar Art 23 credits, exit-tax gain maths beyond the ¥100m threshold gate, non-permanent resident dollar schedules, and MLI article-by-article overrides beyond the WH effect date.

All cells on this page

Common questions

Is Japan tax residence a 183-day test?
No. Domestic Japan residence uses domicile or continuous residence of one year or more. The 183-day figure appears in treaty Art 15 short-stay — not as Japan’s domestic residence test.
What is Japan’s exit tax threshold?
NTA Tax Answer No.1478: covered securities and unsettled derivatives totaling ¥100 million or more, and domicile/residence for more than five years in the prior ten. Gain maths refused. Payment deferral of five years (max ten) exists with conditions.
Is there a Japan–Vietnam tax treaty?
Yes. Signed 24 October 1995; in force from 31 December 1995. MLI withholding effect from 1 January 2024. Article-by-article MLI overrides beyond filed dates are not re-celled.
How is dual JP–VN residence resolved?
When both domestic systems claim you, DTA Art 4 applies (permanent home → centre of vital interests → habitual abode → nationality → mutual agreement). We refuse outcomes without those facts.

Cells cite primary sources with check months. Method · Sources · Disclosure. Not personalised tax advice.

Also filed: Australia · Singapore · South Korea · China · United Kingdom · Canada · United States.

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