Posts Tagged ‘outbound’

Tax controversy – Denso’s Singapore subsidiary a CFC

News, information

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

Foreign dividend exclusion and foreign companies

Japanese taiyaki - fish shaped batter surrounding a sweet bean center - suprisingly good

This post explains the scope of foreign companies to which the Japanese Foreign Dividend Exclusion System (FDES) applies, allowing Japanese companies to exclude the dividends of certain of their affiliated companies from Japanese taxation provided appropriate conditions are met. This post should be read in conjunction with the post discussing Qualifying Distributions that can apply the FDES system. Read More

Japanese Dividend Exclusion system – Qualifying Distributions

Osaka skyline by night

The Foreign Dividend Exclusion System (FDES), recently introduced as a major change to the Japanese tax law, allows certain distributions received by Japanese companies from overseas affiliated entities in which they have a 25% or greater interest (as defined) to be excluded from Japanese taxation. This posting discusses which types of distributions – ‘Qualifying Distributions’ – can apply the FDES system. Read More

Foreign Dividend Exclusion – glossary, definitions

Their convenience in crowded trains is one reason for the ubiquity of mobile phones in Japan

This post summarises some of the key Japanese terms relevant to the recently introduced system that allows Japanese companies to exclude certain foreign dividends (Qualifying Distributions, as explained in this post) received from affiliated companies (as defined) from Japanese taxation. Read More

Cases re Japan CFC – nature of main business

March 25, 2010  |  Japanese CFC  |  No Comments

A lego interpretation of Himeji-jou - a world heritage site

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

2010 Tax Reform and Japan CFCs

March 24, 2010  |  Japanese CFC  |  No Comments

Japanese 2010 tax reform and Japanese CFC taxation.

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Flowchart to determine Japanese CFC status

March 19, 2010  |  Japanese CFC  |  No Comments

Flow chart to work out a subsidiary's status under the Japanese CFC rules.

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Japanese CFCs – “Non Related Person Standard Business”

March 16, 2010  |  Japanese CFC  |  No Comments

The non related business standard and the Japanese CFC regulations.

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Exclusions from the Japanese CFC rules

March 15, 2010  |  Japanese CFC  |  No Comments

Exclusions from the application of the Japanese CFC regulations.

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Scope of the Japanese CFC rules

March 15, 2010  |  Japanese CFC  |  No Comments

Scope of Japanese foreign subsidiaries within the Japanese CFC rules.

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