We are especially proud of our long-standing cooperative relationships with various international networks of law offices.

Tax

A team of tax accountants familiar with international tax provides the tax consulting services described below. We first provide you with a general explanation of your case and a summary of the tax issues free of charge.
As for our fees thereafter, we will try to meet your budget, so please feel free to contact us.

Tax Consultation Services

  • Tax services related to Japanese branches or subsidiaries of foreign corporations
  • International tax consulting services, such as anti-tax haven rules, thin capitalisation rules, and earnings stripping rules
  • Tax consultation for inbound investment structures such as finance and real estate transactions
  • Tax consultation regarding the handling of financial products in and out of Japan
  • Treatment of income tax, inheritance tax and gift tax for foreigners residing in Japan
  • Other general tax affairs

Examples of matters dealt with through inquiries to us

  • Consideration of issues regarding the taxation of foreign investors in Japan, including the application of tax treaties to cases where investments are received from abroad
  • Taxation in the event of investing in investment vehicles using Nini-Kumiai (NK), Tokumei-Kumiai (TK) or trusts in Japan
  • Taxation of investments in foreign financial instruments or partnerships
  • Application of the foreign subsidiary dividend exemption by a Japanese parent company and the controlled foreign company rules (CFC rules or anti-tax haven rules) in the event of establishing a subsidiary overseas
  • Application of foreign tax credit in the event of taxation on foreign source income in a foreign country
  • Restrictions on the inclusion of interest in expenses at a Japanese branch and the treatment of inter-branch transactions based on the new taxation system applicable to foreign corporations (Authorized OECD Approach, AOA)
  • Examination of the necessity of withholding tax for payments to overseas business operators, application of tax treaties and documents to be submitted
  • Confirmation of income tax treatment related to the acquisition and sale of shares acquired through ways such as stock options from an overseas parent company

TAX Services Sachihiko Fujimoto / Naokazu Suga

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