We provide 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
- 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
