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Japan: Administrative guidance on UTPR and QDMTT

Applicable for fiscal years beginning on or after April 1, 2026

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March 30, 2026

The National Tax Agency on March 27, 2026, released the explanation of the administrative guidance, which had been released on January 30, 2026, on the Japanese undertaxed profits rule (UTPR) and qualified domestic minimum top-up tax (QDMTT), which were introduced as part of the 2025 tax reform.

The guidance is for fiscal years beginning on or after April 1, 2026.

Read a March 2026 report prepared by the KPMG member firm in Japan

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