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Japan Tax Bulletin

Taxation of a Nini Kumiai (“NK”), a form of partnership under the Civil Code

An NK is a partnership stipulated in the Civil Code. NKs are sometimes used to design tax shelter products. This bulletin contains an overview of the legal framework of NKs in the Civil Code, tax treatments of NKs, discusses a court case where a judgement was made on a tax shelter structure using an NK and the anti-avoidance rules.

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