Tax controversy – Denso’s Singapore subsidiary a CFC

News, information

The Asahi Newspaper reported in July 2010 that Denso, the largest automotive parts manufacturer in Japan and part of the Toyota group, had received direction during its last tax audit that the company had under-reported JPY11.4Bn Read More

Japanese CFCs – diagrams

July 16, 2010  |  Japanese CFC  |  No Comments

One of many small shops in Tokyo's Akihabara selling computer parts.

This post introduces three diagrams intended to help understand how to determine whether a foreign entity is a Foreign Related Party for THCML, how to determine direct and indirect ownership percentages in different circumstances and also how to calculate the Ownership Ratio used to apply Current Taxation to Japanese resident companies or individuals Read More

Cases re Japan CFC – nature of main business

March 25, 2010  |  Japanese CFC  |  No Comments

A lego interpretation of Himeji-jou - a world heritage site

This post is the first of a series which outlines precedents arising from a number of tax cases that have been heard in the Japanese courts concerning the application of the Japanese tax haven countermeasures law (THCML). These cases provide some useful guidance on the interpretation of the law concerned, but of course proper professional advice should be obtained about their application to a particular taxpayer’s specific circumstances.

The first case addresses the definition of main business for a financial year and also considers what factors are relevant to determining main business. Read More

2010 Tax Reform and Japan CFCs

March 24, 2010  |  Japanese CFC  |  No Comments

Japanese 2010 tax reform and Japanese CFC taxation.

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Flowchart to determine Japanese CFC status

March 19, 2010  |  Japanese CFC  |  No Comments

Flow chart to work out a subsidiary's status under the Japanese CFC rules.

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Japanese CFCs – “Non Related Person Standard Business”

March 16, 2010  |  Japanese CFC  |  No Comments

The non related business standard and the Japanese CFC regulations.

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Exclusions from the Japanese CFC rules

March 15, 2010  |  Japanese CFC  |  No Comments

Exclusions from the application of the Japanese CFC regulations.

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Scope of the Japanese CFC rules

March 15, 2010  |  Japanese CFC  |  No Comments

Scope of Japanese foreign subsidiaries within the Japanese CFC rules.

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Japanese tax haven rules (CFC, Subpart F) – overview/タックスヘイベン対策税制

March 15, 2010  |  Japanese CFC  |  No Comments

Introduction to concepts and scope of the Japanese tax haven countermeasures (CFC) rules.

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