About the Author
List of Abbreviations
Preface
CHAPTER 1 General Taxation in Japan
Q1 Overview of Taxes in Japan
Q2 Overview of Japanese Tax Audits
CHAPTER 2 Withholding Tax
Q3 Scope of Domestic Source Income
Q4 Tax Conventions
Q5 Withholding Tax on Unpaid Dividends
Q6 Exemption from Withholding Tax for Japanese Branches of Foreign Corporations
Q7 Withholding Tax on Dividends and Relief under Tax Conventions
Q8 Withholding Tax on Dividends and Relief under Tax Conventions (Derivative Benefits Test)
Q9 Withholding Tax on Dividends and Relief under Tax Conventions (Active Business Test)
Q10 Withholding Tax on Interest Payments and Relief under Tax Conventions
Q11 Withholding Tax on Inclusion of Interest into Principal
Q12 Withholding Tax on Royalties for Trademarks and Relief under Tax Conventions
Q13 Application of Tax Conventions to Pass-Through Entities
Q14 Withholding Tax on Fees for Use of Tangible Fixed Assets
Q15 Withholding Tax Refund Claims under Tax Conventions
Q16 Exemption from Withholding Tax for Short-Term Business Travellers under Tax Conventions
Q17 Withholding Tax on Directors’ Remuneration Paid to Non-resident Directors
Q18 Withholding Tax on the Provision of Technical Services by Indian Corporations
Q19 Withholding Tax on Share-Based Remuneration Granted by Foreign Corporation
CHAPTER 3 Corporation Tax
Q20 Blue Form Tax Return Status
Q21 Maintenance of Electronic Accounting Books and Records
Q22 Tax Notifications upon Establishment of a Japanese Company
Q23 Calculation of Corporate Taxation for Japanese Subsidiaries of Multinational Corporation
Q24 Calculation of Corporate Tax for Japanese Branches of Foreign Corporations
Q25 Documentation Obligations for PEs
Q26 Fiscal Year for Japanese Tax Purposes
Q27 Tax Treatment of Small- and Medium-Sized Enterprises (SMEs)
Q28 Revenue Recognition for Tax Purposes
Q29 Non-refundable Revenue Received in Advance
Q30 Deductibility of Reasonably Estimated Provisions
Q31 Tax Treatment of Remuneration for Seconded Directors
Q32 Tax Treatment of Net Guaranteed Directors’ Remuneration Paid in Foreign Currency
Q33 Tax Treatment of Charges for Share-Based Compensation
Q34 Acquisition Cost of Inventories for Tax Purposes
Q35 Tax Depreciation of Fixed Assets
Q36 Tax Requirement to Recognise Depreciation Expenses for Accounting Purposes
Q37 Tax Treatment of Bad Debt Losses
Q38 Timing of Deductibility of Corporate Enterprise Tax
Q39 Transfer of Economic Benefit (‘Donation’) to Foreign-Related Corporation
Q40 Deductibility of Entertainment Expenses for Directors of a Foreign Parent Corporation
Q41 Limitation of Tax Losses Carried Forward
Q42 Exchange Rates for Foreign Currency Transactions
Q43 Definition of Permanent Establishments (PE)
Q44 Commissionaire Transactions and PE
Q45 Overview of Transfer Pricing Taxation
Q46 Deductibility of Transfer Pricing Adjustment
Q47 Donations to Foreign-Related Corporations and Transfer Pricing
Q48 Transfer Pricing Documentation Obligations
Q49 Notification of Ultimate Parent Entity
Q50 Transfer Pricing and Hidden Profit Distributions
Q51 Additional Corporation Tax under the Family Corporation Tax Regime
Q52 Foreign Tax Credits
Q53 Taxation on the Transfer of Shares of a Japanese Corporation
Q54 Tax Treatment on Reorganisation of a Parent Corporation
Q55 Deemed Dividend on Capital Reduction
Q56 Thin Capitalisation and Earnings Stripping Rules
Q57 Tax Treatment upon Dissolution and Liquidation of a Japanese Godo Kaisha (GK) Subsidiary
Q58 Tax Treatment on Dissolution of a Japanese Branch
CHAPTER 4 Corporate Enterprise Tax
Q59 Factor-Based Taxation for the Japanese Branch of a Foreign Corporation
Q60 Calculation of Factor-Based Taxation for a Japanese Branch of a Foreign Corporation
CHAPTER 5 Consumption Tax
Q61 Transactions Subject to Consumption Tax
Q62 Reduced Tax Rates
Q63 National and Local Consumption Taxes
Q64 Interim Consumption Tax Returns
Q65 Simplified Consumption Tax Returns
Q66 Timing of Input Consumption Tax Credit
Q67 Revenue Recognition and Consumption Tax
Q68 Taxable and Exempt Enterprises for Consumption Tax Purposes
Q69 Base Period for Foreign Corporations
Q70 Consumption Tax Refunds for Foreign Corporations
Q71 Shortening of the Consumption Taxable Period
Q72 Consumption Tax-Exempt Sales (Election to Become a Taxable Enterprise)
Q73 Consumption Tax-Exempt Sales (Sales to Foreign Embassies)
Q74 Sales and Purchases of Goods Located in Japan by a Foreign Corporation
Q75 Provision of Services to Non-residents (Storage of Goods in Japan)
Q76 Reimbursement of Expenses
Q77 Tax Treatment of Transfers of Assets Outside Japan
Q78 Tax Treatment of the Cross-Border Supply of Electronic Services (B2B Transactions)
Q79 Tax Treatment of the Cross-Border Supply of Electronic Services (B2C Transaction)
Q80 Requirement to Become a Registered Foreign Service Provider
Q81 Itemised Method and Proportional Method
Q82 Input Consumption Tax Credits for Purchases Related to Sales Outside Japan
Q83 Tax Treatment of Transfers of Small Value Assets: Invoices
Q84 Foreign Exchange for Foreign Currency Transactions
Q85 Consumption Tax Treatment on Bad Debt Losses
Q86 Japanese Invoice System
Q87 Consumption Tax Account Summary
