This page collates posts and resources related to the Japanese Tax Haven Countermeasures regulations in the Japanese tax code. This is equivalent to the US or UK CFC legislation intended to define and tax currently certain categories of Japanese outbound investment.
Articles on Japanese Tax Haven Countermeasures regulations
08/20/2010 • The Asahi Newspaper reported in July 2010 that Denso, the largest automotive parts manufacturer in Japan and part of the...Read More
07/16/2010 • This post introduces three diagrams intended to help understand how to determine whether a foreign entity is a Foreign Related...Read More
03/25/2010 • This post is the first of a series which outlines precedents arising from a number of tax cases that have...Read More
03/19/2010 • Flow chart to work out a subsidiary's status under the Japanese CFC...Read More
03/16/2010 • The non related business standard and the Japanese CFC...Read More
03/15/2010 • Exclusions from the application of the Japanese CFC...Read More
03/15/2010 • Scope of Japanese foreign subsidiaries within the Japanese CFC...Read More
03/15/2010 • Introduction to concepts and scope of the Japanese tax haven countermeasures (CFC)...Read More
This flowchart helps determine the taxation status of Japanese CFCs.This diagram gives an example of how to determine whether a foreign company is a Foreign Related Party for THCML purposes.
This diagram illustrates how to calculate the Ownership Ratio for direct and indirect holdings of shares in a Foreign Related Company.
This diagram illustrates who will be liabile and how to calculate the Ownership Ratio on which Japanese residents will be subject to Current Taxation under the THCML for a Specified Foreign Subsidiary.