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Webinar language: Japanese
Like in the Netherlands, and many other OECD countries, Japan has introduced various measures in the last few years to combat perceived tax avoidance by multinational enterprises. In particular Japan has put the overseas structures and activities of its global corporations under greater scrutiny.
One of such measures is the recent fundamental revision of Japan's tax rules (also referred to as "Controlled Foreign Companies" or "CFC" rules). The updated rules more closely reflect the OECD's recommendations from its comprehensive Base Erosion and Profit Shifting (BEPS) project.
In order to stay compliant with the new CFC rules, Japanese multinational corporations and their foreign subsidiaries may need to revisit their group structure. Should they fail to respond adequately, then income of such foreign subsidiaries might become taxable in Japan. This holds especially true for structures involving overseas holding and/or financing companies, or other types of SPCs, that do not (predominantly) conduct active business activities. For these companies, having a sufficient level of local substance and/or management and control is becoming increasingly important.
On top of the changes to the CFC rules, Japanese multinational corporations are facing a rapidly changing tax landscape in the Netherlands and elsewhere in the world, with substance requirements being enhanced and measures aimed to counter treaty shopping being introduced.
In this webinar we team up with PwC Tax Japan and the Netherlands and provide our insights on:
- the main aspects of the recent Japanese CFC reforms
- the impact of recent Dutch tax developments as well as the changing international tax landscape (for Japanese corporations); and
- how to respond adequately to these changes from a global tax compliance point of view
- TMF Group is the organizer and jointly presenting with PwC.
This webinar is focused on Japanese MNCs and their overseas subsidiaries (individuals responsible for corporate tax governance).
