Archive for July, 2010

Japanese CFCs – diagrams

July 16, 2010  |  Japanese CFC  |  No Comments

One of many small shops in Tokyo's Akihabara selling computer parts.

This post introduces three diagrams intended to help understand how to determine whether a foreign entity is a Foreign Related Party for THCML, how to determine direct and indirect ownership percentages in different circumstances and also how to calculate the Ownership Ratio used to apply Current Taxation to Japanese resident companies or individuals Read More

The new Singapore Japan protocol

July 9, 2010  |  Tax Treaties  |  No Comments

Japanese koi, a relative of the carp family

This is one of a number of brief posts summarising recent 2010 Japanese tax treaty developments.

On 14 June 2010 the revised protocol to the Singapore Japan tax treaty became effective.  The protocol, which can be found here, revises only Article 26 of the existing Singapore Japan treaty in clarifying mutual obligations Read More

Dividend Taxation – Japanese companies’ capital account

The Mejiro or White Eye a charming Japanese native bird about the size of a sparrow

This post is the first in a series looking at how the return of funds to shareholders is treated for Japanese tax purposes.  Funds can be returned to a company’s shareholders through dividends, deemed dividends, share-buy backs, return of surplus on a liquidation and other transactions (below ‘Shareholder Distributions’).

In order to understand how Shareholder Distributions are taxed Read More