The German Ministry of Finance has published an agreement signed with Japan on 4 June 2025 regarding the application of the arbitration procedures under paragraph 5 of Article 24 (Mutual Agreement Procedure) of the 2015 tax treaty between the two countries. Paragraph 5 provides that if a person's case cannot be resolved within 2 years, any unresolved issues arising from the case shall be submitted to arbitration if the person so requests. For this purpose, the agreement covers, among other t…