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International Taxation Change to the Attributable Income Principle (AOA)

International Taxation Change to the Attributable I ...

A report titled ‘Tax reform regarding a change from the Entire Income Principle (the Force of Attraction Principle) to the Attributable Income Principle’ (‘AOA Report’) was submitted by the Ministry of Finance to a meeting of the International Taxation Discussion Group of the government’s Tax Commission on 24 October 2013.

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We set out in this newsletter the points/effects of the tax reform expected to be included in the 2014 tax reform and the outline of the AOA Report.

(The AOA (Authorised OECD Approach) is an approach developed by the OECD to calculate income attributable to a permanent establishment.)

Contents

  1. Points of the Tax Reform and the Effects thereof
  2. Outline of the AOA Report

Japan TAX Newsletter

© 2020 KPMG AZSA LLC, a limited liability audit corporation incorporated under the Japanese Certified Public Accountants Law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. © 2020 KPMG Tax Corporation, a tax corporation incorporated under the Japanese CPTA Law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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