Steps completed for entry into force of protocols to US treaties

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September 2019


The US Treasury announced on August 30, through a press release, that the remaining diplomatic steps to permit the entry into force of the protocols to the US tax treaties with Spain and Japan have been completed. As provided in the protocols, this means that the protocol to the treaty with Spain will enter into force three months from the date of completion, on November 27, 2019. In addition, the protocol to the treaty with Japan entered into force on August 30, 2019. There are varying effective dates for specific provisions.

The takeaway

Of the four treaty protocols that were approved by the US Senate in July 2019, those with Spain and Japan either have been cleared for entry into force (Spain) or have already entered into force (Japan). Those with Switzerland and Luxembourg have not yet entered into force, as the appropriate diplomatic notifications/exchange of instruments of ratification have not yet occurred.

Renegotiated or new treaties with Hungary, Poland, and Chile remain pending Senate consideration.

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Oren Penn

Principal, US Inbound Tax and International Tax Services, PwC US

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