Archive for June 22nd, 2010

Japan 2010 tax reform – deferral of tax on intra group transactions

June 22, 2010  |  basics, Business combinations  |  No Comments

Pine trees are typically planted at the gate to large shrines.

This post outlines the rules introduced in the Japanese 2010 tax reform that allow sales of certain assets to be made between defined Japanese entities within a group of wholly owned companies without immediately recognizing taxable gain or loss.  This system is referred to in Japanese as the グループ内取引等に関する税制・guruupu nai torihiki tou ni kansuru zeisei, translated below as the ‘Intra Group Transactions Tax System’ abbreviated as IGTS.  The system should apply to transactions from 1 October 2010 onwards but professional advice from qualified Japanese tax professionals must be taken to confirm how the system can be applied. Read More