Archive for August 21st, 2010

Thin capitalisation – diagrams

Thin capitalisation in Japan

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

2010 tax reform and deemed dividends

2010 tax reform and dividends

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