Introduction to TMK taxation – the Japanese real estate SPC

November 23, 2010  |  Entities, Real Estate, TMK  |  No Comments

Detail taken from a 'mikoshi' or Japanese portable shrine kept for use in local festivals.

The ‘TMK’ (in Japanese the ‘特定目的会社’ or ‘tokutei mokuteki kaisha’ )、a special purpose entity commonly used in Japanese real estate transactions, is regarded as having a corporate nature for Japanese tax purposes and hence is taxed as a corporation rather than as a fiscally transparent entity.

However, a number of special tax provisions apply to the entity introduced in order to help promote the securitization of assets held under the TMK structure. Read More

Introduction to the Japanese Real Estate SPC or ‘TMK’

November 22, 2010  |  Entities, Real Estate, TMK  |  No Comments

A sumo wrestler preparing the training ring in the sumo training house or 'Sumo Beya'

The Japanese authorities first took steps to help encourage liquidity in the Japanese real estate market through the introduction of a conduit entity that could be used in real estate transactions prior to 2000, when the ‘Law Concerning the Liquidation of Specified through a Special Purposes Company’ (in Japanese the ‘特定目的会社による特定資産の流動化に関する法律’ or ‘or tokutei mokuteki kaisha ni yoru tokutei no shisan non ryudouka ni kansuru houritsu’ and referred to be low as the ‘SPC Law’) Read More