Tax Articles | AQ Partners Blog

Capital Increase and Capital Reduction in Japan: Procedure, Tax Effects, and the ¥100 Million Threshold

Capital Increase and Capital Reduction in Japan, AQ Partners

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Capital Increase and Capital Reduction in Japan: Procedure, Tax Effects, and the ¥100 Million Threshold

How a foreign-owned Japan subsidiary increases or reduces capital: resolutions, creditor notices, 0.7% and ¥30,000 registration taxes, FEFTA, and the ¥100M line

Tax

Entity

Yuga Koda

Founding Director

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Permanent Establishment Risk Before the Entity Exists: Remote Employees, EORs, and Sales Reps in Japan

Permanent Establishment Risk Before the Entity Exists, AQ Partners

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Permanent Establishment Risk Before the Entity Exists: Remote Employees, EORs, and Sales Reps in Japan

How remote employees, EOR hires, distributors, and representative offices create a permanent establishment in Japan before a subsidiary exists.

Tax

Entity

Yuga Koda

Founding Director

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Aligning the Japan Subsidiary's Fiscal Year with the Parent: Options, Filings, and the Cost of Changing Later

Aligning the Japan Subsidiary's Fiscal Year with the Parent, AQ Partners

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Aligning the Japan Subsidiary's Fiscal Year with the Parent: Options, Filings, and the Cost of Changing Later

Why a Japan subsidiary should match its parent's fiscal year end, what a short first period does to tax deadlines and thresholds, and how to change it later.

Accounting

Tax

Yuga Koda

Founding Director

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Repatriating Profits from Japan: Dividends vs Royalties vs Capital Reduction

Repatriating Profits from Japan, AQ Partners

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Repatriating Profits from Japan: Dividends vs Royalties vs Capital Reduction

Dividends vs royalties vs capital reduction for a Japan subsidiary: 20.42% withholding, US and UK treaty relief, deemed dividends, and a worked ¥100M example.

Tax

Entity

Yuga Koda

Founding Director

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Intercompany Management Fees and Service Agreements for Japan Subsidiaries: Deductibility and Documentation

Intercompany Management Fees for Japan Subsidiaries, AQ Partners

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Intercompany Management Fees and Service Agreements for Japan Subsidiaries: Deductibility and Documentation

How a Japan subsidiary deducts management fees paid to its foreign parent: the three NTA conditions, cost plus 5% pricing, withholding, and documentation.

Tax

Accounting

Yuga Koda

Founding Director

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Intercompany Loans to a Japan Subsidiary: Interest Rates, Withholding, and FEFTA Reporting

Intercompany Loans to a Japan Subsidiary, AQ Partners

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Intercompany Loans to a Japan Subsidiary: Interest Rates, Withholding, and FEFTA Reporting

How a foreign parent lends to its Japan subsidiary: arm's length interest, 20.42% withholding and treaty relief, the FEFTA loan test, 45-day report, FX rules.

Tax

Banking

Yuga Koda

Founding Director

AQ Partners Blog

Your information hub for Japan back office.

Capital Increase and Capital Reduction in Japan: Procedure, Tax Effects, and the ¥100 Million Threshold

Permanent Establishment Risk Before the Entity Exists: Remote Employees, EORs, and Sales Reps in Japan

Aligning the Japan Subsidiary's Fiscal Year with the Parent: Options, Filings, and the Cost of Changing Later

Repatriating Profits from Japan: Dividends vs Royalties vs Capital Reduction

Intercompany Management Fees and Service Agreements for Japan Subsidiaries: Deductibility and Documentation

Intercompany Loans to a Japan Subsidiary: Interest Rates, Withholding, and FEFTA Reporting

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