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With the COVID-19 travel restrictions lifted, business travel has increased significantly. Some companies assume their employees are tax-exempt if their home country has an income tax treaty with the host country and the employee spends not more than 183 days in aggregate there. How to count the days can easily create confusion. This edition of the tax bulletin explains how to count 183 days and pitfalls you need to be aware of when counting travel days to Japan.

The global tax landscape is experiencing a historic transformation as countries implement the OECD/G20’s Pillar Two framework—an initiative designed to introduce a Global Minimum Tax (GMT) of 15% on large multinational enterprises (MNEs). Japan has taken a proactive role in adopting and legislating this framework, aligning its domestic laws with the OECD’s model rules while tailoring certain elements to suit its national tax policy objectives. This article provides an overview of the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Minimum Top-up Tax (QDMTT) as implemented in Japan, highlights key dates, compares Japan’s approach with OECD recommendations, and explains the rules’ impact on Japanese corporations.

The quality of AI outputs is improving with a pace too significant for it to be discounted. The oft repeated phrase is that AI and automation is ideal for tasks that are repetitive, follow a specific set of rules, and take a long period of time with manual input. For example, current AI can assimilate information from a Local File and use this to evaluate the comparability of comparable companies based on their business description and other information, providing acceptance and rejection reasons accordingly.

The 2025 fiscal year, known as Reiwa 7 in Japan, brings several changes to the corporate tax landscape. These reforms aim to enhance corporate competitiveness, encourage investment, and ensure fair taxation. This bulletin outlines the key aspects of the Reiwa 7 corporate tax reforms, based on the latest publications by the Japan Ministry of Finance.

In December 2024, The Japan National Tax Agency (NTA) has recently issued an update correction to Form of Statement Concerning Foreign Tax Credit for an individual resident taxpayer for 2022 calendar year and thereafter. This correction is concerning foreign income taxes on distribution of collective investment trust income.

2020 年10 月23 日付の日本経済新聞は『海外財産逃さない』「国税当局、徴収で国際連携」において、国際間の「徴収共助」制度を利用した海外当局への徴収要請件数が、2019 事務年度において、過去最多の29 件となったことを報じています。東京国税局は、この「徴収共助」を利用して、韓国の税務当局と連携し、日本国内の滞納税額800 万円を徴収したとされています。