Government Notifies India–Japan Tax Collection Assistance Agreement
The Ministry of Finance has issued Notification No. 56/2026 dated 2 April 2026, giving effect in India to the Memorandum of Understanding (MoU) for Assistance in Collection of Taxes between the Government of India and the Government of Japan.
The MoU has been executed under Article 26A of the Double Taxation Avoidance Convention (DTAA) between the two countries and has been notified under Section 90 of the Income-tax Act, 1961.
What is the Purpose of this Notification?
The notification enables the implementation of the MoU that lays down the operational framework for mutual assistance in the collection of tax claims between India and Japan.
This means that, subject to the provisions of the DTAA and the MoU, the tax authorities of both countries can cooperate in recovering tax dues requested by the other country.
Key Highlights
- Notification No.: 56/2026
- Date of Notification: 2 April 2026
- Issued by: Ministry of Finance, Department of Revenue
- Covers: Assistance in Collection of Taxes between India and Japan
- Legal Basis: Section 90 of the Income-tax Act, 1961 read with Article 26A of the India–Japan DTAA.
Effective Date
The notification clarifies that the Memorandum became effective in India from 8 July 2025, being the later of the dates on which it was signed by the competent authorities. Accordingly, it applies to requests for tax collection made after that date.
Why is this Important?
This notification strengthens tax cooperation between India and Japan by providing a clear mechanism for cross-border recovery of tax dues. It also supports international efforts to improve tax compliance and reduce tax evasion in cross-border transactions.
Official Notification
Notification No. 56/2026 dated 2 April 2026 – Ministry of Finance (Department of Revenue)
Official PDF: https://www.incometaxindia.gov.in/documents/d/guest/ennotification-no-56-2026-pdf
