Japan: Additional guidance on income inclusion rule
The National Tax Agency released guidance in the form of Q&As on income inclusion rule
The National Tax Agency released guidance in the form of Q&As on income inclusion rule
The National Tax Agency on 25 December 2023 released guidance in the form of questions and answers (Q&As) on the income inclusion rule (IIR), which was introduced as part of the 2023 tax reform measures to implement the Pillar Two global minimum tax and will apply to Japanese companies for fiscal years beginning on or after 1 April 2024. Read TaxNewsFlash
The Q&As provide guidance on:
- Enterprise groups
- Specified multinational enterprise (MNE) groups
- Ownership interest
- Calculation of net global anti-base erosion (GloBE) income
- Adjusted covered tax
- Top-up tax
- Transitional country-by-country (CbC) reporting safe harbor
Read a December 2023 report [PDF 134 KB] prepared by the KPMG member firm in Japan
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.