Archive for October, 2010

Correcting Japanese withholding tax errors

October 4, 2010  |  Withholding tax  |  No Comments

Ema - wooden plaques on which a person writes their wish and ties to a fence or tree in the temple grounds.

Under the Japanese withholding tax system the Payor of Japanese source income on which withholding tax applies has an obligation to withhold the tax concerned and pay it over to the tax authorities.  A Payor who withholds insufficient tax may be liable to penalties and interest in respect of the underpayment.  Procedures also exist to repay the Payor for certain taxes incorrectly over-withheld. Read More

The Japanese ‘Fixed Place of Business’ PE

October 3, 2010  |  Taxable Presence  |  No Comments
The 'Ohara Hadaka Matsuri' or 'Ohara Naked Festival', held once a year in Chiba. The shrine is carried in a rush into the sea.

The 'Ohara Hadaka Matsuri' or 'Ohara Naked Festival' held once a year in Chiba. The shrine is carried in a rush into the sea.

A long established convention of international tax law is that in order for the business income of a company to be taxable in a foreign country, the company must have a ‘permanent establishment’ or ‘PE’ in the foreign country concerned through which its business is conducted.

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Dividend withholding tax rates under Japan’s tax treaties

October 2, 2010  |  Withholding tax  |  2 Comments
Kagura dancer, part of Shinto festival rites and an ancestor of the Noh tradition

Kagura dancer, part of Shinto festival rites and an ancestor of the Noh tradition

The table linked to this article summarizes the withholding tax rates on dividends under Japan’s different tax treaties.

The withholding tax rate on dividends under Japan’s model tax treaty is 15 per cent for portfolio investments and 5 per cent for dividends from parent-subsidiary shareholdings. Read More

First results from Japan, Cayman Islands information exchange

October 1, 2010  |  Developments, News  |  No Comments

News, information

The Asahi Newspaper reported on 30 September 2010 that, by 29 September 2010, the Japanese tax authorities had received responses to many of their requests for information from the Cayman Island tax authorities.

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