Once a company is profitable, this one arrives eventually. The mechanics of paying a dividend look simple: approve the financial statements, pass the dividend resolution alongside them, pay it. The complications are all around the edges.

The treaty application

Assuming a treaty country, filing the application is what gets you the reduction or exemption from withholding on the dividend. If you are claiming under a limitation-on-benefits article, Form 17 — the attachment for the limitation-on-benefits provision — has to be filed as well. This is the one that gets missed on a first filing.

Dividends are typically far larger than an ordinary vendor payment, so the cost of a missed filing is correspondingly large. If an accounting manager at a foreign-owned company is not aware of the treaty position on dividends at all, that says something uncomfortable about the wider technical baseline.

Two things that are not tax at all

The Bank of Japan filing. A “Report on Payments or Receipt of Payments” is required. The bank will usually prompt you for it, but it is worth knowing it exists rather than discovering it on the day.

Your own transfer limit. If you remit through e-banking, your contract with the bank sets a daily transfer ceiling. I have heard of dividends exceeding that ceiling and failing at the remittance stage more than once. It is a five-minute check well before payment date.