The agent PE under Japanese domestic tax law

One of more than two hundred and fifty bars clustered into the Golden Gai area in Shinjuku. Usually there is only seating for a half dozen or so people.

Japanese domestic tax law and related Tax Instructions include detailed regulations addressing when a person in Japan acting as an agent on behalf of a foreign company can create a taxable presence – a permanent establishment or ‘PE’ – of the foreign company in Japan. Read More

The Japanese ‘Fixed Place of Business’ PE

October 3, 2010  |  Taxable Presence  |  No Comments
The 'Ohara Hadaka Matsuri' or 'Ohara Naked Festival', held once a year in Chiba. The shrine is carried in a rush into the sea.

The 'Ohara Hadaka Matsuri' or 'Ohara Naked Festival' held once a year in Chiba. The shrine is carried in a rush into the sea.

A long established convention of international tax law is that in order for the business income of a company to be taxable in a foreign country, the company must have a ‘permanent establishment’ or ‘PE’ in the foreign country concerned through which its business is conducted.

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PEs under Japan’s tax treaties

March 6, 2010  |  Tax Treaties, Taxable Presence  |  No Comments

The scope of PEs under different tax treaties.

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