Q&A on Japanese Taxation for Multinational Corporations

Given its prominence among the world's major industrial jurisdictions, Japan is involved in numerous multinational corporate transactions, and its extensive and complex tax regime inevitably plays an important role. This unique book, with its easy-to-use Q&A format, provides succinct and authoritative responses to most of the questions that tax professionals operating in or doing business with Japan are likely to face in practice. The author, a well-known Japanese international tax specialist, has organised eighty-seven questions around tax issues he has consulted on over more than twenty years of direct experience in advising international businesses.

The questions, all based on actual examples, cover every area of tax practice, including the following:

• tax notifications upon establishment of a Japanese company;

• foreign tax credits;

• transfer pricing documentation obligations;

• tax treatment of small- and medium-sized enterprises;

• exemption from withholding tax for Japanese branches of foreign corporations;

• withholding tax on royalties for trademarks and relief under tax conventions;

• withholding tax on directors' remuneration paid to non-resident directors;

• maintenance of electronic accounting books and records;

• tax treatment of bad debt losses;

• deductibility of entertainment expenses;

• sales and purchases of goods located in Japan by a foreign corporation; and

• tax treatment of the cross-border supply of electronic services.

The English translations of terms used in Japanese taxation and tax practice are designed to facilitate understanding for non-Japanese tax practitioners.

As an overview of Japanese tax issues that may be faced in the realm of international business, this incomparable book provides tax professionals with a wealth of expertise that may be readily applied to any tax strategy involving a business transaction with a Japanese element. It will be welcomed by in-house corporate counsel, taxation academics, and tax lawyers worldwide.