Archive for March 30th, 2010

Thin capitalisation – tax filing schedule

Light summer kimono's - Yukata in Japanese

Attached here is the form required in a Japanese tax return that is used to calculate the leverage ratios required for thin capitalisation purposes (see this post for details) and hence any disallowance of interest for Japanese thin capitalisation purposes.

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.

Foreign dividend exclusion and foreign companies

Japanese taiyaki - fish shaped batter surrounding a sweet bean center - suprisingly good

This post explains the scope of foreign companies to which the Japanese Foreign Dividend Exclusion System (FDES) applies, allowing Japanese companies to exclude the dividends of certain of their affiliated companies from Japanese taxation provided appropriate conditions are met. This post should be read in conjunction with the post discussing Qualifying Distributions that can apply the FDES system. Read More