Japan has seen many changes in its approach to taxing corporate groups in recent years with the introduction of consolidated taxation, group-reorganization rules and in 2010 rules allowing deferral of taxation on certain intra-group transactions.
The Japanese corporate law has also seen significant reform in this period, Read More
This post outlines the rules introduced in the Japanese 2010 tax reform that allow sales of certain assets to be made between defined Japanese entities within a group of wholly owned companies without immediately recognizing taxable gain or loss. This system is referred to in Japanese as the グループ内取引等に関する税制・guruupu nai torihiki tou ni kansuru zeisei, translated below as the ‘Intra Group Transactions Tax System’ abbreviated as IGTS. The system should apply to transactions from 1 October 2010 onwards but professional advice from qualified Japanese tax professionals must be taken to confirm how the system can be applied. Read More
Japanese 2010 tax reform and Japanese CFC taxation.Read More