Course Introduction

Suitable for those new to international taxation to understand.

Start international tax

• Duration：Approximately 35 minutes
• Fee：JPY 6,200

In order to make it easier for those new to international taxation to understand, the basic points of the main international taxation systems are explained in an easy-to-understand way, using dialogue, charts, etc., based on examples of transactions in overseas business by Japanese companies.

Suitable for those with domestic tax experience, who wish to expand their international tax understanding.

International business development and taxation

• Speaker：Akio Nabetani
• Duration：Approximately 40 minutes
• Fee：JPY 6,200

An easy-to-understand explanation of the tax implications related to international business development, considering the manner of expansion and the type of transactions engaged in, for both outbound expansion from Japan and inbound expansion into Japan.

Controlled foreign company rules

• Speaker：Yumiko Arai
• Duration：Approximately 90 minutes
• Fee：JPY 19,800

An outline of Japan’s controlled foreign company rules, including their purpose and application; the classification of foreign subsidiaries under the rules; the analysis of local business activities under the rules; the criteria for exemption from the rules; calculation of tax where the rules apply; and more.

Foreign tax credits and foreign dividend exemption system

• Speaker：Hiroki Ono
• Duration：Approximately 70 minute
• Fee：JPY 19,800

An explanation of the purpose and application of both foreign tax credits and the foreign subsidiary dividend exemption system.

Tax treaties

• Speaker：Akio Nabetani
• Duration：Approximately 50 minutes
• Fee：JPY 13,800

Tax treaty basics and an overview of Japan’s tax treaty network.

Transfer pricing

• Speakers：Toru Fujisawa、Toshiyuki Yamaoka
• Duration：Approximately 60 minutes
• Fee：JPY 13,800

Transfer pricing taxation from both the technical and practical perspectives.

Thin capitalisation, earnings stripping, and anti-corporation inversion measures

• Speaker：Masahiko Asakura
• Duration：Approximately 50 minutes
• Fee：JPY 15,800

Purposes and application of the thin capitalization and earnings stripping rules to manage excessive interest deductions, and anti-corporate inversion measures.

Taxation of the digital economy

• Speaker：Haruhisa Shirato
• Duration：Approximately 40 minutes
• Fee：JPY 6,200

Background to the international initiatives related to taxation of the digital economy, led by the OECD, with a specific focus on Pillar 1 and Pillar 2.

Suitable for tax professionals with an understanding of the basics, but who wish to deepen their knowledge in key areas of current focus in Japan and globally.

Controlled foreign corporations (1): foreign affiliates and applicable domestic corporations

• Speaker：Akio Nabetani
• Duration：Approximately 60 minutes
• Fee：JPY 17,800

A more detailed dive into the controlled foreign corporation rules, including criteria used to identify foreign affiliated companies and applicable domestic corporations.

Controlled foreign corporations (2): analysis of economic activity and calculation of CFC charge

• Speaker：Akio Nabetani
• Duration：Approximately 90 minutes
• Fee：JPY 27,800

A more detailed dive into the controlled foreign corporation rules, including an analysis of the economic activities standard, and calculation of CFC charge.

Controlled foreign corporations (3): calculation of taxable income

• Speaker：Akio Nabetani
• Duration：Approximately 60 minutes
• Fee：JPY 17,800

A more detailed dive into the controlled foreign corporation rules, including calculation of the taxable income of the foreign corporation, whether on a total company basis or for CFC income only.

Controlled foreign corporations (4): adjustments to relieve double taxation and other practical measures

• Speakers：Akio Nabetani、Takuya Nakahara、Yumiko Arai、Kazuhiro Obara
• Duration：Approximately 60 minutes
• Fee：JPY 17,800

A more detailed dive into the controlled foreign corporation rules, including calculation of the taxable income of the foreign corporation, whether on a total company basis or for CFC income only.

Foreign tax credits (1): creditable foreign corporate tax and credit limits

• Speaker：Morito Yamada
• Duration：Approximately 70 minutes
• Fee：JPY 21,800

The impact of corporate taxes paid overseas, the calculation of creditable foreign corporate tax, limits on the amount of credits available, and more.

Foreign tax credits (2): reporting of foreign tax credits; special provisions for reduction in book value of subsidiaries

• Speakers：Morito Yamada、Takuya Nakahra、Masahiko Asakura、Kazuhiro Obara
• Duration：Approximately 70 minutes
• Fee：JPY 21,800

The purpose and application of the tax credit carry-forward system, and relationship with the group tax relief regime. An overview of the special provisions relating to reduction in book value of subsidiaries.

Suitable for experienced tax professionals, who wish to expand their knowledge of specific tax technical matters, such as M&A.

Taxation of Japanese multinational enterprises

• Speaker：Akio Nabetani
• Duration：Approximately 50 minutes
• Fee：JPY 21,800

A detailed explanation of the tax implications of global business operations, both in Japan and globally, including the impact of different types of business structures and transactions, with reference to both the Japanese and foreign tax systems.

M&A and international taxation

• Speaker：Yoshie Yagi
• Duration：Approximately 40 minutes
• Fee：JPY 21,800

Practical tax issues arising from cross-border M&A, with a specific focus on the impact under the Japanese tax law, at each stage of the process, from pre- to post-acquisition.