The Asahi Newspaper reported in July 2010 that Denso, the largest automotive parts manufacturer in Japan and part of the Toyota group, had received direction during its last tax audit that the company had under-reported JPY11.4Bn Read More
This post is the first of a series which outlines precedents arising from a number of tax cases that have been heard in the Japanese courts concerning the application of the Japanese tax haven countermeasures law (THCML). These cases provide some useful guidance on the interpretation of the law concerned, but of course proper professional advice should be obtained about their application to a particular taxpayer’s specific circumstances.
The first case addresses the definition of main business for a financial year and also considers what factors are relevant to determining main business. Read More
Japanese 2010 tax reform and Japanese CFC taxation.Read More
Flow chart to work out a subsidiary's status under the Japanese CFC rules.Read More
The non related business standard and the Japanese CFC regulations.Read More
Exclusions from the application of the Japanese CFC regulations.Read More
Scope of Japanese foreign subsidiaries within the Japanese CFC rules.Read More