Deemed dividends – concept, transactions

July 19, 2010  |  Dividend Taxation, Domestic, Featured  |  No Comments

Mount Fuji from the air, of course.

As explained in this post introducing the Japanese Dividends Received Deduction (‘DRD’), Article 23-1 of the Japanese Corporate Tax Law recognises that, in order to mitigate double taxation of corporate profits, certain distributions to shareholders of corporate surplus Read More

The Japanese Dividends Received Deduction

Banners from Jonangu Shrine in Kyoto. http://www.jonangu.com/

This post is the first in a series looking at Article 23 of the Japanese Corporate Tax Law which is the main article dealing with the Japanese Dividends Received Deduction (‘DRD’).  In particular this post addresses paragraph 1 in Article 23 which defines which types of payment by a company or other entities to its members or shareholders are eligible for the DRD  (i.e. which payments are ‘DRD Dividends’). Read More

Dividend Taxation – Japanese companies’ capital account

The Mejiro or White Eye a charming Japanese native bird about the size of a sparrow

This post is the first in a series looking at how the return of funds to shareholders is treated for Japanese tax purposes.  Funds can be returned to a company’s shareholders through dividends, deemed dividends, share-buy backs, return of surplus on a liquidation and other transactions (below ‘Shareholder Distributions’).

In order to understand how Shareholder Distributions are taxed Read More

Japanese international tax – FAQs

June 12, 2010  |  Featured, International Taxation  |  No Comments

A statue of the Buddha in Yanaka, Tokyo near Nippori station

This post collates together frequently asked questions relating to Japanese international tax issues.   Common issues in international tax include identifying whether income has a source in a particular country and hence may be within the scope of the taxing jurisdiction of the authorities of the country concerned; whether tax treaties amend or alter the scope of such jurisdiction or mitigate the rate of tax paid and how the matters intrinsic to an enterprise – for example their residence or whether or not they fiscally transparent – impacts the rights of a country to impose tax.  This and other issues are discussed in the international tax section (see the drop down menu) but to start off with below are a series of Japanese international tax FAQs. Read More

“Blue form” filing status

"Blue Impulse" - the Japanese Air Self Defense Force formation flying group

This post gives an overview of the role of the “blue form tax return” in the Japanese tax system. A Japanese taxpayer becomes a “blue form” tax filer by submitting an election to the authorities and then maintaining their accounting records to an acceptable standard. Read More

Tokumei kumiai taxation – outline

February 11, 2010  |  Featured, Tokumei Kumiai  |  No Comments

Diagrams and overview of TK taxation.

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