International Taxation Change to the Attributa ... - KPMG Japan
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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.)


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

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