Thin Capitalisation



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Below are articles outlining the basic thin capitalisation rules in Japan. Later articles will outline the application to specific industries and transactions.

Case study: Thin cap - matters equivalent to a guarantee

Case study: Thin cap – matters equivalent to a guarantee

02/10/2011 • The following case study considers whether or not a transaction that does not have the legal form of a guarantee may still...Read More

Case study: Thin cap and stock borrowing

Case study: Thin cap and stock borrowing

02/09/2011 • The following article is a case study looking at the application of the Japanese thin capitalisation regulations to a stock...Read More

Thin capitalisation - diagrams

Thin capitalisation – diagrams

08/21/2010 • This article consists of three diagrams which illustrate how the Japanese thin capitalisation regulations are applied. The first diagram...Read More

Dividend Taxation - Japanese companies' capital account

Dividend Taxation – Japanese companies’ capital account

07/05/2010 • This post is the first in a series looking at how the return of funds to shareholders is treated for...Read More

Thin capitalisation -  tax filing schedule

Thin capitalisation – tax filing schedule

03/30/2010 • Attached here is the form required in a Japanese tax return that is used to calculate the leverage ratios required...Read More

Thin capitalisation rules in Japan

Thin capitalisation rules in Japan

02/25/2010 • Thin capitalization – kashou shihon zeisei The Japanese thin capitalization system is intended to prevent foreign over-leveraging their Japanese subsidiaries or...Read More