The form has been annotated in English to show the information required to complete the calculations required for Japanese thin capitalisation purposes.
The original form can be found here on the NTA website. Of course, proper professional advice should be sought before completing the form for real.
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
This article has a selection of FAQs around basic Japanese corporate taxation together with links to more detailed articles for each topic discussed.
Please do not hesitate to add comments or further questions as these can form the basis of further FAQ items in due course.
Japanese 2010 tax reform and Japanese CFC taxation.Read More
Rates of withholding tax on interest under Japan's tax treaties.Read More
The source of income is a critical concept for international tax purposes given it will usually define the extent to which a particular country taxes the income of foreign persons. A foreign company which has Japanese source income as defined under Japan’s domestic law may be subject to Japanese tax Read More
Flow chart to work out a subsidiary's status under the Japanese CFC rules.Read More