PwC Financial Services Tax News

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2014

September
Impact on J-REIT taxation by amendent of Cabinet Order regarding investment scope of J-REITs and invetsment trusts[PDF 137KB]
On 3 September 2014, an amended Cabinet Order of the Law concerning Investment Trust and Investment Companies (“ITIC Law Cabinet Order”) was issued and, in conjunction, the Special Taxation Measures Law Enforcement Orders were also amended.
In particular, the revisions to the ITIC Law Cabinet Order allow investment trusts and J-REITs to invest in specified assets such as renewable energy facilities and concessions for public facilities. On the other hand, J-REITs must meet the “assets tests”, in order to claim deductibility of dividends, and where additional assets are not to be treated as qualified assets.
August
Revisions to the Corporation Tax Law Basic Circulars regarding amendment of the Japanese tax principle of international taxation [PDF 140KB]
On 15 July 2014, Japan’s National Tax Agency issued amended Corporate Tax Basic Circulars to align the Japanese tax principle of international taxation with the authorized OECD approach (“AOA”) as enacted by the 2014 Tax Reforms.
In particular, the revisions to the Basic Circulars provide new guidance on the application of intra-entity dealing and cost allocation.
April
2014 tax reform for the financial services industry & real estate market in Japan [PDF 166KB]
In this newsletter, we focus on the 2014 Tax Reforms and their impact in relation to the financial services industry and real estate market in Japan.