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2020 Tax Reform Proposals - Revision to Consolidated Tax Return Filing System

Revision to Consolidated Tax Return Filing System

By virtue of the 2020 tax reform, the Consolidated Tax Return Filing System will be revised fundamentally to the new so-called Japanese Group Relief System.

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We have set out the KPMG Japan Tax Newsletter featuring the main points of the revision to the Consolidated Tax Return Filing System (Shift to the Japanese Group Relief System) included in the Proposal.

Contents

          Background of the Proposal
          Main Points of the Proposal

  1. Applicable Companies
  2. Application Method
  3. Filing and Tax Payments
  4. Crystallization of Built-in Gains/Losses at the Start of or at the Time of Participation in the Japanese Group Relief System
  5. Write-off of Tax NOLs and Restriction on Usage of Tax NOLs and Unrealized Losses on Certain Assets at the time immediately before the Start of or Participation in the Japanese Group Relief System 
  6. Calculation of Taxable Income and Corporation Tax Liability
  7. Withdrawal from the Aggregation Group
  8. Other
  9. Timing of Application

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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