Archive for September, 2010

Information exchange under Japan’s tax treaties

September 15, 2010  |  International Taxation, Latest, Tax Treaties  |  No Comments

A colorful display of Japanese kanji

An objective of Japan’s 2010 tax reform program has been the extension of the network of tax treaties that allow Japan to exchange taxpayer information with tax authorities in other jurisdictions.  Such extension should be of help in allowing Japan to more effectively pursue international tax evasion.

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Resident, non-permanent resident and non-resident

September 14, 2010  |  Individual  |  No Comments

Sumo wrestlers celebrating

Residency for tax purposes is a critical issue for any expatriate coming to Japan to do business.  Residency status determines whether or not an individual has to file a Japanese tax return and, if he or she does have to file such a return, the scope of the income which is reported on the return and taxed in Japan. Read More

Japanese dividend taxation for individuals

September 14, 2010  |  Dividend Taxation, Individual  |  No Comments

Japanese monkeys enjoying an onsen in Nagano-ken

This article outlines how individuals are taxed on dividend income for Japanese tax purposes.

As so often seems the case with Japanese individual taxation, what would be expected to be a simple tax matter is made overly complicated by a range of expiring tax benefits (that are often revised or extended) Read More

The new Netherlands Japan tax treaty

September 14, 2010  |  International Taxation, Tax Treaties  |  No Comments
Signing ceremony for the new Netherlands Japan tax treaty

Signing ceremony for the new Netherlands Japan tax treaty

On August 25th 2010 the new Japan Netherlands tax treaty (below the ‘Treaty’) was signed between Mr. Koichi Takemasa, State Secretary for Foreign Affairs of Japan and His Excellency Dr. Philip De Heer, Ambassador Extraordinary and Plenipotentiary of the Kingdom of the Netherlands to Japan. Read More

Japanese entities – pass-through or taxable as corporations

September 10, 2010  |  basics  |  No Comments
Venn diagram showing tax status of Japanese entities

Venn diagram showing tax status of Japanese entities

Recent years have seen a significant expansion in the types of trusts, partnerships and corporations that can be formed in Japan.

Understanding which entities are pass-through for tax purposes, which entities are taxed as corporations Read More

Contributing assets for shares

September 9, 2010  |  Business combinations  |  No Comments
Steller's Sea Eagle taken in Shiretoko Hokkaido

Steller's Sea Eagle taken in Shiretoko Hokkaido

A common transaction in a group reorganization is the contribution by a company of assets other than monetary assets in exchange for shares in another company. Such a transaction would typically occur in an incorporation transaction or perhaps in the process of consolidating subsidiaries under a single parent company. Read More

Introduction to Japanese tax groups – definitions

September 7, 2010  |  Group Taxation  |  No Comments

A mask used in Japanese Noh theater

Japan has seen many changes  in its approach to taxing corporate groups in recent years with the introduction of consolidated taxation, group-reorganization rules and in 2010 rules allowing deferral of taxation on certain intra-group transactions

The Japanese corporate law has also seen significant reform in this period, Read More

Round up of Ministry Proposals for 2011 tax reform

September 7, 2010  |  News, Policy  |  No Comments

Government policy

Japanese Government Ministries have completed submissions outlining their hoped for changes in 2011 tax legislation. These are collated on the Japanese Cabinet Office website (links in Japanese). Read More

Proof of payment of Japanese corporate tax

September 4, 2010  |  basics, Domestic  |  No Comments

Receipt evidencing Japanese tax payment

One seemingly trivial issue which can have great practical importance is obtaining proof that a Japanese company has paid its corporation tax liability.

Evidence of such tax payment is often critical for foreign tax credit purposes or for due diligence purposes. Below is an outline of the Japanese tax payment process with examples in English Read More