Posts Tagged ‘tax assessment’

Tax Controversy – Panasonic taxed on “donation” to Chinese subsidiary

August 4, 2010  |  basics, Developments, Financing, News  |  No Comments

News, information

The Asahi Newspaper reported on 2 August 2010 that the major household electronics manufacturer Panasonic had been subject to an assessment for JPY22Bn Read More

Tax Controversy – Daiei taxed on forgiveness of debt to subsidiaries

July 31, 2010  |  Corporate Recovery, Developments, News  |  No Comments

News, information

Japanese retailer Daiei was assessed JPY25Bn (USD294m @85) for understating taxable income for four years.  The Asahi newspaper reported as follows: Read More

Corporations – statute of limitations

February 1, 2010  |  Corporate tax administration  |  No Comments

Hanko - used in Japan to execute legal documents

One of the most commonly asked questions in Japanese tax due diligence or risk assessment (including FIN48) is how the statute of limitations operates for Japanese tax purposes. There are some important differences between the Japanese system and the US and UK or UK based approaches, with some key points being as follows:

Comparing Japan to US and UK

In contrast to the US, where failure to file certain tax returns (such as those required by a permanent establishment of a foreign company in the US) can leave an open ended exposure that will not expire with time, in Japan the expiration of the statue of limitations over time will in due course mean that historic liabilities will fall out of the period allowed for assessment, although the timing is extended for failure to make filings when due. Read More