PwC Japan Tax Update

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2014 Tax Reform Proposal [PDF 359KB]
This newsletter illustrates the major components of the 2014 Tax Reform Proposal with regard to corporate taxpayers.
Release of Report on Introduction of Attribution Rule to the Taxation of Permanent Establishments [PDF 182KB]
This article summarizes the fundamentals of the potential amendments to the taxation of PEs and the impact this would have on Japanese and foreign corporations and non-resident individuals.
Background to the potential revision to the Japanese tax rules for attributing profits to permanent establishments [PDF 174KB]
This article explores the contextual background to the report, the rationale for any change and where it may lead. This article is published together with our technical newsletter on MOF's report, as a complementary analysis.
Consumption tax increase and investment incentive proposals [PDF 269KB]
On October 1, 2013, the Cabinet Office announced the formal decision to go ahead with the consumption tax increase from April 1, 2014 as planned. In addition, the Cabinet Office announced the new “Economic Policy Package” to soften the economic impact of the consumption tax increase.
OECD's Action Plan published on Base Erosion and Profit Shifting (BEPS) [PDF 189KB]
An Action Plan has been published on 19 July 2013 by the Organisation for Economic Cooperation and Development (OECD) with a view to addressing the perceived flaws in the international tax rules that were discussed in the OECD's February 2013 Base Erosion and Profit Shifting (BEPS) report.
Consumption Tax Amendment Update [PDF 229KB]
On August 10, 2012 the "Tax Hike Bill" related to social security reforms was approved in the upper house of the Japanese Diet. Related regulations were issued on March 13 and March 18, 2013. This Japan Tax Update provides a summary of the regulations and a review of the current items under discussion.
Significant update on tax audit procedures
This issue highlights the revision of the Act on General Rules for National Taxes (clarification of audit procedures) and its impact on corporate tax audits commencing from January 1, 2013.
2013 Tax Reform Proposal
The 2013 tax reform proposal submitted by the Cabinet Office's Tax Commission, known as Taiko, (“2013 Tax Reform Proposal”) was released on January 29, 2013 upon approval by the Cabinet. The proposed tax law changes will be submitted to the Diet during February 2013 for consideration.
A New Protocol to the US-Japan Tax Treaty [PDF 143KB]
This Japan Tax Update provides a summary of a new protocol to the income tax treaty between the United States and Japan, which was signed by Treasury Deputy Secretary Neal S. Wolin and Japan's Ambassador to the United States Kenichiro Sasae on January 24, US time (January 25, Japan time).
Updates on the status of Tax Treaties/Agreements [PDF 137KB]
This Japan Tax Update provides a summary of the tax treaties and agreements that entered into force or were signed by Japan since January 1, 2012.