Japanese CFCs



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

Tax controversy - Denso's Singapore subsidiary a CFC

Tax controversy – Denso’s Singapore subsidiary a CFC

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

Japanese CFCs - diagrams

Japanese CFCs – diagrams

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

Cases re Japan CFC - nature of main business

Cases re Japan CFC – nature of main business

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

2010 Tax Reform and Japan CFCs

2010 Tax Reform and Japan CFCs

03/24/2010 • Japanese 2010 tax reform and Japanese CFC...Read More

Flowchart to determine Japanese CFC status

Flowchart to determine Japanese CFC status

03/19/2010 • Flow chart to work out a subsidiary's status under the Japanese CFC...Read More

Japanese CFCs -

Japanese CFCs – “Non Related Person Standard Business”

03/16/2010 • The non related business standard and the Japanese CFC...Read More

Exclusions from the Japanese CFC rules

Exclusions from the Japanese CFC rules

03/15/2010 • Exclusions from the application of the Japanese CFC...Read More

Scope of the Japanese CFC rules

Scope of the Japanese CFC rules

03/15/2010 • Scope of Japanese foreign subsidiaries within the Japanese CFC...Read More

Japanese tax haven rules (CFC, Subpart F) - overview/タックスヘイベン対策税制

Japanese tax haven rules (CFC, Subpart F) – overview/タックスヘイベン対策税制

03/15/2010 • Introduction to concepts and scope of the Japanese tax haven countermeasures (CFC)...Read More

Diagrams, flowcharts

This flowchart helps determine the taxation status of Japanese CFCs.

Foreign Related Company determination

This diagram gives an example of how to determine whether a foreign company is a Foreign Related Party for THCML purposes.





Calculation of direct and indirect holding

This diagram illustrates how to calculate the Ownership Ratio for direct and indirect holdings of shares in a Foreign Related Company.





Ownership Ratio

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.