In recent years, improved legal and tax regulations for Japanese real estate investment and securitization have led to increased interest in real estate funds in/outside of Japan, as well as the creation of real estate liquidation and securitization products. Companies interested in investing in Japanese real estate through tokutei mokuteki kaisha (TMK) or tokumei kumiai (TK) vehicles need to pay careful attention to how they structure their investments to ensure the desired outcomes. For Japanese real estate investment trusts (REITs), it is essential to have professional advisors familiar with issues such as the tax cost of various transactions, reorganizations such as mergers, and REIT specific accounting and tax adjustments. In order to create the appropriate structures for overseas investment, it is necessary to consider a wide range of issues including tax treaties, tax treatment of different kinds of entities including partnerships in Japan, transfer pricing, and the taxation of permanent establishments (PE).
We provide a full range of tax consulting and compliance services for real estate investments, listed REITs, private REITs, and other kinds of real estate related companies (such as renewable energy companies). We can also provide detailed services for structuring TKs and TMKs and suggest structures depending on the type of investment and nature of the operations. In the case of international real estate operations, we can deliver tax advice related to country-specific taxation through our global network of PwC member firms.