China – Japan Tax Treaty
The China-Japan tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, and interest at 10%. Royalties are taxed at a uniform 10% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in China's network and one of 47 in Japan's. The general dividend rate of 10% compares to a median of 10% across China's network and 15% across Japan's.
Verified data
Japan Ministry of Finance Tax Conventions (mof.go.jp) (Treaty list verified April 2026 (as of Dec 19, 2025). Rates from individual treaty texts.)
Withholding Rate Summary
Source: Japan Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Japan) |
|---|---|---|
| Dividends (general) Portfolio investors | 10%saves 10% | 20% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 15% | 20% |
| Interest Bank interest, bonds, loans | 10%saves 10% | 20% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 10% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Japan)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 20%.
Source: Japan Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 20% statutory rate. This represents a 10% reduction from the statutory rate.
Source: Japan Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 10% to 10%.
Source: Japan Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Japan Treaty Reference
Comparative Context
🇨🇳China's Network
Among China's 47 active treaty partners, the 10% general dividend rate ranks 22th (median: 10%).
| Partner | Rate |
|---|---|
| Ireland | 10% |
| India | 10% |
| Italy | 10% |
| Japan (this treaty) | 10% |
| South Korea | 10% |
| Luxembourg | 10% |
| Mexico | 10% |
🇯🇵Japan's Network
Among Japan's 47 active treaty partners, the 10% general dividend rate ranks 3rd (median: 15%).
| Partner | Rate |
|---|---|
| United Arab Emirates | 10% |
| Switzerland | 10% |
| China (this treaty) | 10% |
| France | 10% |
| United Kingdom | 10% |
| Hong Kong | 10% |