This page collates together posts and resources related to Japanese domestic corporate tax issues other than those dealt with elsewhere in sections on corporate reorganisation, financing and similar. Examples of topics dealt with here include the Japanese dividends received deduction for domestic shares, the taxation of Japanese intangible assets and domestic tax incentives.
Filings, assessments, penalties
This section looks at administrative aspects of Japanese domestic taxation with initial focus on areas that may risk creating financial exposures for foreign investors through late or unfiled tax returns or from liability to interest and penalties. The Japanese system is very unforgiving to late filers with few grounds for mitigation.
The tax treatment of intangible assets under the tax code is a domestic issue that often has very material implications for foreign investors, especially in relation to the acquisitions of Japanese companies or in relation to transfer pricing or international tax planning. The section includes information on lives of intangible assets as well as information on the different types of assets recognised in the tax code.
The taxation of shareholder distributions covers dividends, repayments of share capital and repurchase of own shares and a number of other transactions that are often central to corporate reorganisations or to the ultimate realisation of gains from an investment in Japan.