Archive for August 11th, 2010

Group relationships in Japanese tax

August 11, 2010  |  basics, Group Taxation  |  No Comments

Group relationships for Japanese tax purposes

The diagram to the right in this post outlines two group relationships defined for Japanese corporate tax purposes. These are the Japanese Consolidated Tax group, that allows offset of losses within the Japanese group, and the IGTS group, that allows the transfer if assets between Japanese corporate members of the group without giving rise to gain or loss. Read More

Tax Controversy – authorities challenge merger qualification

News, information

Softbank’s reported results for the three month period ended 30 June 2010 included JPY26.4Bn in respect of an assessment to taxes raised on its subsidary, Yahoo Japan, received from the Tokyo Regional Tax Bureau (TRTB) on 30 June 2010.  Read More

Tax Controversy – disallowance of related company recharges

News, information

The Asahi Newspaper reported on 11 August 2010 that Hewlett Packard’s Japanese subsidiary (‘Japan HP’) had received an assessment in respect of JPY47Bn (USD550m) unreported income. Read More