2010 tax reform and deemed dividends

2010 tax reform and dividends

This article outlines an anti-avoidance measure included in the 2010 tax reform that prevents a shareholder applying the Japanese Dividends Received Deduction (‘DRD’) on a Deemed Dividend arising on the purchase by a company of its own shares. Read More

Dividends and Attributable Interest

Wagashi traditional Japanese sweets often reflecting the seasons

The Japanese Dividends Received Deduction (‘DRD’) helps mitigate the double taxation a company would otherwise suffer through tax on dividends the company receives from other Japanese companies.  However the DRD regulations also include provisions that effectively disallow financing costs that are attributable to dividends to which the DRD is applied.  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