Business Office Taxation in Japan
JAPAN TAX BULLETINThis article introduces the Business Office Tax, which needs to be considered when entities conduct business in offices or workplaces within cities with a population of 300,000 or more.
2021/12/171 min read

Due to the prolonged Covid-19 pandemic, more and moreJapanese companies are selling off their headquarter buildings and other real estate holdings in order to secure cash reserves and drastically downsize their office space.
Among the buyers are foreignfunds, foreign corporations, and wealthy foreign individuals.
In thisbulleting, we will review the tax treatment of a foreign corporation and a non-resident individual that leases office space in Japan to a Japanese company or a Japanese resident.
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This article introduces the Business Office Tax, which needs to be considered when entities conduct business in offices or workplaces within cities with a population of 300,000 or more.
Starting in 2027, a revised minimum tax regime will apply to certain high-income individuals in Japan. While JPY165 million is used as a calculation threshold, additional tax is only triggered where the minimum tax exceeds the regular income tax liability. The reform is intended to ensure a minimum level of taxation, particularly where a significant portion of income is derived from investment or equity-based sources.
In recent years, international tax authorities have intensified scrutiny of cross-border structures involving low-substance entities, commonly referred to as “paper companies.” Japan is no exception and such structures continue to be examined under existing anti-avoidance frameworks, including the “Controlled Foreign Company (CFC) regime and treaty-based anti-abuse rules.
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