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In general, a foreign corporation without a permanent establishment (PE) in Japan is not subject to capital gains tax on the disposal of shares in a Japanese company. However, there are some exceptions to the general rule. The Japan 2018 Tax Reform Proposal amends one of the exceptions as summarized below.
We summarize the Japan 2018 Tax Reform Proposal related to resident individual income taxpayers as below. Broadly speaking, this proposal contains tax increases for high-income individuals. All amendments below are scheduled to be effective for individual income tax on or after 2020.
The 2018 Tax Reform broadens a definition of Agent PE under the domestic tax law in Japan. This amendment above is effective for fiscal years of corporation beginning on or after January 1, 2019.
We are delighted to announce that Suga Professional Tax Services has started offering Japanese tax services.