Operational Information

Relief at source – Japan – CFCL (Vestima)

CFCL | Japan CFCL

Reference

Service level
CFCL
Last Updated
17.11.2025

Relief at source from withholding tax on dividends from Japanese listed ETFs and REITs is available through Clearstream Fund Centre for eligible beneficial owners as follows:

  • For residents of DTT countries, the applicable rate is the tax treaty rate or 15.315%, whichever is lower.
  • For tax-exempt entities (such as International or Supranational organisations), the applicable rate is 0%.

Documentation requirements

To obtain relief at source from withholding tax on income from Japanese listed ETFs and REITs, the documentation must be provided to Clearstream Fund Centre before the respective dividend payment date (see “Deadlines for receipt of documents” below).

The documentation requirements vary according to the status of the beneficial owner, as follows.

For residents of DTT countries

Clients holding Japanese listed ETFs or REITs for multiple beneficial owners (including themselves when applicable) must submit the following documentation:

  • One-Time Certificate for Japanese Listed ETFs and REITs, signed and completed by the client and valid until revoked;
  • Payment Breakdown per payment via Clearstream Fund Centre’s Upload Beneficial Owner List facility, giving details of the taxable beneficial owners and the respective DTT rates requested.

Clients holding Japanese listed ETFs or REITs for themselves only, as sole beneficial owner, must submit the following documentation:

  • One-Time Certificate for Japanese Listed ETFs and REITs – Own Assets, signed and completed by the client and valid until revoked;
  • A one-time Payment Breakdown via Clearstream Fund Centre’s Upload Beneficial Owner List facility, giving details of the DTT rate requested; and
  • A Payment Breakdown Confirmation Message, via Swift MT599 or CFS Web Portal free-format message to be sent to "Attn: Singapore Tax Team - SIT", confirming that the Payment Breakdown sent on the respective date is valid until revoked.

For specific types of beneficial owner applying to obtain relief at source according to a DTT, the following documentation is requested in addition, as indicated:

  • Certificate of Residence (COR), issued by the beneficial owner’s local tax authorities for:- All eligible beneficial owners under DTT with Limitation On Benefits Article;
    - U.S. individuals;
    - U.S. investment vehicles (such as mutual funds etc.);
    - German individuals (only for German beneficial owners holding Japanese listed  ETFs);
    - Zambian beneficial owners;
    - Chilean eligible beneficial owners (eligible pension funds).

The Certificate of Residence is valid for three years as from the date of submission of the Form 17 to the Japanese Tax Office (except for U.S. investment vehicles and German beneficial owners applying for DTT, the Certificate of Residence is valid for one year as from the date of submission of the Form 17 to the Japanese Tax Office).

For Chilean and Zambian eligible beneficial owners, the Certificate of Residence is valid for one year as from the date of issuance.

  • Form 17 Attachment Form for Limitation On Benefits Article should be provided by the following beneficial owners:

    - All eligible beneficial owners under DTT with Limitation On Benefits Article (excluding eligible individuals, pension funds, pension scheme). 
    - U.S. investment vehicles (such as mutual funds etc.) - Part B, C or D must be completed, as applicable;

    N.B.: Form 17 for eligible beneficial owners under DTT with Limitation On Benefits Article that are individuals and pension funds, pension scheme will be filled in by the Depository and submitted to the Japanese Tax Office directly.

    N.B.: Beneficial owners who should fill in Part B of Form 17 may opt to complete the “Declaration Letter” (see below) instead of Part B of the Form 17 but a Form 17 is, nevertheless, required.

The Form 17 is valid for three years if any line of part A Section 3 of the form applies. The Form 17 is valid for one year if any line of part B, C or D Section 3 of the form applies. The validity of the form starts as from the date of submission of the Form 17 to the Japanese Tax Office.

  • Declaration Letter - For beneficial owners for whom Part B on Form 17, normally applicable, has not been completed and for French (for example, SICAV and FCP) investment vehicles such as mutual funds. The form is valid for one year from the date of issuance.

    Note: For French investment vehicles, no Form 17 is needed.

    Please note that Form 17 and COR will only be submitted by the depository to the Japanese Tax Office once the full set of documents is received. Therefore, in case of submission without an upcoming income payment, a “single” Payment Breakdown via Clearstream Fund Centre’s Upload Beneficial Owner List facility, giving details of the taxable beneficial owners and the respective DTT rates requested (clients may use a “dummy” isin and payment date) must be submitted together with Form 17 and COR. 

    Without a valid “single” Payment Breakdown, Form 17 and COR will be rejected. Subsequently, clients still need to submit a Payment Breakdown per payment.

In case of upcoming income payment, Form 17 and COR (when applicable) should be in place and valid at the Record Date and Payment Date of the income event to obtain a reduced tax rate or exemption.

For tax-exempt entities (such as International or Supranational organisations)

Clients holding Japanese listed ETFs or REITs for multiple beneficial owners (including themselves when applicable) must submit the following documentation:

  • One-Time Certificate for Japanese Listed ETFs and REITs, signed and completed by the client and valid until revoked;
  • Payment Breakdown per payment via Clearstream Fund Centre  Centre’s Upload Beneficial Owner List facility, giving details of the taxable beneficial owners and the respective DTT rates requested.

Clients holding Japanese listed ETFs or REITs for themselves only, as sole beneficial owner, must submit

  • One-Time Certificate for Japanese Listed ETFs and REITs – Own Assets, signed and completed by the client and valid until revoked;
  • A one-time Payment Breakdown via Clearstream Fund Centre’s Upload Beneficial Owner List facility, giving details of the DTT rate requested; and
  • A Payment Breakdown Confirmation Message, via Swift MT599 or CFC Web Portal free-format message to be sent to "Attn: Singapore Tax Team - SIT", confirming that the Payment Breakdown sent on the respective date is valid until revoked.

In addition, for all tax-exempt entities, the following documentation must be submitted:

  • Copy of the Official Certification (for example, founding documents), valid until revoked;
  • Power of Attorney to Clearstream Fund Centre (in the original) executed by the final beneficial owner granting Clearstream Fund Centre the right to request tax relief at source, valid until revoked (unless there is a change in the beneficial owner’s details).

    N.B.: In case of a client holding third party assets, the Power Of Attorney from the Beneficial Owner to Clearstream Fund Centre should be supplemented with a Cover Letter signed by the Clearstream Fund Centre client (two authorised signatories) and confirming that the signatures on the Power Of Attorney are true and valid.

For residents of Japan that are individuals

  • Payment Breakdown, submitted via Clearstream Fund Centre’s Upload Beneficial Owner List facility, per payment in order to have the correct tax rate of 20.315% (15.315% national tax + 5% local tax) applied.

    N.B.: When completing the Payment Breakdown, 15.315% should be specified (and not 20.315%, as the file refers to national tax only. The 5% local tax will, however, be deducted in addition to the 15.315% when processing the payment to a Japanese individual, resulting in an effective tax rate of 20.315%.

Additional documentation

All clients may be requested to provide the following additional documentation upon request:

  • Proof of tax residence for beneficial owners that are eligible to obtain a reduced rate of withholding tax at source; and
  • Any other tax documentation every now and then.

​​​​​​​Deadlines for receipt of documents

Documentation for relief at source from withholding tax on dividends must be received by Clearstream Fund Centre according to security type, as follows:

  • For Japanese listed REITs: at the latest five business days after the first income record date, by 10:00 CET, and, for each per-payment Payment Breakdown only, at the latest five business days after each income record date, by 10:00 CET;
  • For Japanese ETFs: at the latest three business days after the first income record date, by 10:00 CET, and, for each per-payment Payment Breakdown only, at the latest three business days after each income record date, by 10:00 CET.