PwC Japan Tax Update

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Supreme Court Decision on Delaware Limited Partnerships [PDF 461KB]
On July 17, 2015, the Japan Supreme Court overturned a lower court (Nagoya High Court) decision and determined that Delaware Limited Partnerships (LPs) should be considered foreign corporations under Japanese tax law, thus denying real estate losses taken by individual taxpayers who entered into the investments.
Double Tax Treaty with Germany [PDF 66KB]
The governments of Japan and Germany have reached an agreement in principle on a draft for a revised Double Tax Treaty.
Based upon the expected review and ratification process, the Treaty would have to be signed by the end of this year in order to become effective on January 1, 2017.
New Japanese consumption tax rules on cross-border digital services [PDF 307KB]
On March 31, 2015 the 2015 Tax Reform Act became law which includes the new Japanese Consumption Tax rules for the provision of services via telecommunication lines. This issue summarizes the new tax regime for the provision of Digital Services.
2015 Tax Reform Act [PDF 490KB]
On 31 March, 2015, the 2015 Tax Reform Act was approved by the Diet and on the same date, the 2015 Tax Reform Act, the Enforcement Orders, and Regulations were promulgated, which are effective for corporate tax years beginning on or after 1 April, 2015.
2015 Tax Reform Proposal [PDF 396KB]
The ruling parties approved the 2015 Tax Reform Proposal taking consideration of certain guidelines prepared by the Cabinet. This newsletter outlines the major components of the 2015 Tax Reform Proposal with regard to corporate taxpayers.