On 24 August 2010 the Japanese Ministry of Economics and Industry (METI) commented on their hoped for tax reforms of 2011. This follows their consultation with industry bodies in July – schedule and documentation here (link in Japanese). Read More
This article explains the definition of ‘Special Relationship’ (特殊の関係) for Japanese tax purposes as applied to individuals. This definition is used in different contexts in the Japanese tax law, for example as part of the process of determining whether or not a company is Family Company for Japanese tax purposes. Read More
This article is an outline of the taxation of Japanese corporate reorganizations, focusing on mergers and looking at the key criteria that will determine how Ceasing KK in the merger will be taxed.
Please also see this article for diagrams with an outline of Japanese merger transactions and this article with an overview of the accounting treatment of Japanese enterprise combinations.
This article Read More
The articles looks at which accounting standards apply, the different categories of enterprise combinations defined in those standards and finally how purchase accounting Read More
The Financial Tax Review Committee (FTRC) (link in Japanese), one of the tax committees within the Japanese Ministry of Finance, commenced reviewing the feasibility of introducing a Japanese Individual Retirement Account (‘Japan IRA’) at their meeting of 29 July 2010. Read More
This article consists of three diagrams which illustrate how the Japanese thin capitalisation regulations are applied. The first diagram illustrates the most straightforward application of the rules, the second illustrates the impact of a parent company guarantee Read More
This article outlines an anti-avoidance measure included in the 2010 tax reform that prevents a shareholder applying the Japanese Dividends Received Deduction (‘DRD’) on a Deemed Dividend arising on the purchase by a company of its own shares. Read More
The Asahi Newspaper reported in July 2010 that Denso, the largest automotive parts manufacturer in Japan and part of the Toyota group, had received direction during its last tax audit that the company had under-reported JPY11.4Bn Read More