Significant 2012 deferred tax write downs for Japanese companies

May 31, 2012  |  Developments, News  |  No Comments

News, information

On the 30th of May, 2012, the Nikkei Newspaper reported on the extent to which leading Japanese companies were required to mark down deferred tax assets for Japanese financial reporting purposes in the year to 31 March 2012.

Read More

Audits of Japanese Corporate Reorganizations.

August 28, 2011  |  Developments, News  |  No Comments

News, information

In recent months the Japanese specialist tax press has reported on the increasing number of Japanese tax audits focusing on Japanese tax preferred corporate reorganizations (below “Japanese TPCRs’) . Please see the corporate reorganization section for details Read More

Japanese taxation of a US Spin-off

August 6, 2011  |  Court, Dividend Taxation  |  No Comments

Japanese judicial decisions

On 21 April 2011 the Tokyo High Court handed down a decision concerning whether shares acquired by a Japanese resident individual further to a spin off by an American company should be treated as dividend income for Japanese income tax purposes. Read More

Taxpayer victory over blue form revocation

August 1, 2011  |  Court, News  |  No Comments

Japanese judicial decisions

On 1 December, 2010 the Tokyo Tax Tribunal found in favor of an individual taxpayer who had protested against the revocation of their “blue form” filing status following an audit. Read More

Tax avoidance and the Takefuji case

March 1, 2011  |  Court, News  |  No Comments

Japanese judicial decisions

On 18th February 2011 the Japanese Supreme Court handed down a decision in favor of the heir of the Japanese consumer finance company, Takefuji, in a case relating to individual tax residence for Japanese tax purposes.. Read More

Japanese tax litigation: Takefuji, hostesses and the ‘Rule of Law’

February 25, 2011  |  Court, News  |  No Comments

News, information

On the 19 February the Japanese Nikkei Newspaper published an article commenting on recent trends in Japanese tax litigation.  The article outlined a number of high profile cases that the Japanese tax authorities had lost in recent months Read More

Passage of 2011 tax incentives for foreign companies progresses

February 22, 2011  |  Developments, News  |  No Comments

News, information

On the 11th February the Asahi Newspaper reported on the progress of 2011 tax reform proposals introducing tax preferences for certain foreign groups establishing subsidiaries in Japan (below the ‘Asian Base Promotion’ proposals and in Japanese the ‘アジア拠点化推進法案’ or ‘ajia kyotenka suishin houan’). Read More

2011 tax reform proposals published

December 16, 2010  |  News, Policy  |  No Comments

News, information

After much public and press discussion, on 14 December 2010 the Japanese Tax Commission announced their main proposals for 2011 tax reform.  These proposals – for individual, corporate, consumption and other taxes – are still subject to the drafting of detailed legislation and approval by the Japanese Diet Read More

Debate on 2011 tax reform reaching a peak

December 9, 2010  |  News, Policy  |  No Comments

News, information

On the 9th of December 2010, the Nikkei Keizai Shimbun reported on a meeting held the previous day of all members of the Japanese Tax Commission (the ‘JTC’). The timing of the meeting reflects the approaching end of year deadline to finalize plans for 2011 tax reform. Read More

Debt equity swap taxation

December 9, 2010  |  Corporate Recovery, Court  |  No Comments

Japanese judicial decisions

On 15 September 2010 the 12th division of the Tokyo High Court issued a judgment concerning the taxation of gain arising from the extinguishment of debt in a debt equity swap (‘DES’) transaction. Read More