Archive for February, 2010

Corporations – statute of limitations

February 1, 2010  |  Corporate tax administration  |  No Comments

Hanko - used in Japan to execute legal documents

One of the most commonly asked questions in Japanese tax due diligence or risk assessment (including FIN48) is how the statute of limitations operates for Japanese tax purposes. There are some important differences between the Japanese system and the US and UK or UK based approaches, with some key points being as follows:

Comparing Japan to US and UK

In contrast to the US, where failure to file certain tax returns (such as those required by a permanent establishment of a foreign company in the US) can leave an open ended exposure that will not expire with time, in Japan the expiration of the statue of limitations over time will in due course mean that historic liabilities will fall out of the period allowed for assessment, although the timing is extended for failure to make filings when due. Read More