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Japanese CFC Regime - 2017 Tax Reform -

Japanese CFC Regime - 2017 Tax Reform -

Under the 2017 tax reform, the Japanese CFC regime has been extensively amended.

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We have set out in this newsletter a brief summary of the amendments to the Japanese CFC regime.

Contents

  1. Overview of the Amendments
  2. Definition and Classification of CFCs
  3. Full-Inclusion Rules
  4. Passive Income Inclusion Rules (Non-Financial CFCs)
  5. Passive Income Inclusion Rules (Financial CFCs)
  6. Taxpayer & Taxable Full-Inclusion Income/Taxable Partial-Inclusion Income
  7. Other Amendments
  8. Points To Be Considered

Japan TAX Newsletter

© 2021 KPMG AZSA LLC, a limited liability audit corporation incorporated under the Japanese Certified Public Accountants Law and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved. © 2021 KPMG Tax Corporation, a tax corporation incorporated under the Japanese CPTA Law and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.


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