On 24 June 2025, the Financial Services Agency (hereinafter ‘FSA’) released the inquiry document containing the results of the inquiry to the National Tax Agency (hereinafter ‘NTA’) about the tax treatments of the Japanese Earnings Stripping Regime (hereinafter ‘J-ESR’) on the FSA’s website (Japanese only), after confirming the purpose and objectives of the J-ESR with the Ministry of Finance.
The inquiry document summarizes the meaning of ‘payments economically equivalent to interest’ included in the ‘interest payments’, which are the basis for calculating the ‘covered interest payments’ subject to the J-ESR and in response to the inquiry to the NTA, the FSA’s view on this inquiry document was confirmed as being acceptable by the NTA.
We have set out in this e-Tax News outline of the inquiry document.
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