Qualified Invoice Registration for a New Japan Subsidiary

Qualified invoice issuer registration is the National Tax Agency (NTA) registration that allows a business in Japan to issue invoices its customers can use to claim input tax credit under consumption tax (消費税, shohizei). Since the qualified invoice system started on 1 October 2023, only a registered qualified invoice issuer (適格請求書発行事業者, tekikaku seikyusho hakko jigyosha) can issue a qualified invoice, and only a taxable business can be registered. For a new Japan subsidiary, the date that matters is the last day of its first taxable period. If the application reaches the NTA by then and asks for registration from the first day, the company is treated as registered from its date of establishment.

Key Takeaways

• The deadline is the end of the first taxable period. Filing by then backdates registration to incorporation.
• Weekends and holidays give no extra time. A deadline falling on a weekend, public holiday or 29 to 31 December does not move.
• The T-number is built from the corporate number. Customers check it, together with the registered corporate name and head office address, on the NTA's public register.
• Customers lose credit on unregistered suppliers. From October 2026 a buyer can credit only 70% of the tax on an invoice without a valid T-number, so procurement asks for it before signing.
• Plan invoicing for the processing gap. e-Tax applications take about two months, so invoices issued before the notice need the T-number supplied afterwards.

Registration Timeline from Incorporation

A new subsidiary can apply at any point in its first business year; in practice the steps run from incorporation to e-Tax access to an NTA notice.

For a corporation, the first taxable period runs from the date of establishment to the first fiscal year end in the articles. A subsidiary incorporated on 1 November with a March year end has five months to file. The wider tax rules are set out in our pillar on Japan consumption tax for a foreign-owned subsidiary.

From incorporation to the registration notice

Nothing can be filed until the NTA has designated the company's corporate number (法人番号, hojin bango) after the incorporation registration, and online filing needs e-Tax access, which a new company does not have on day one. The other filings due after incorporation run in parallel. Review times below are the NTA's estimate of registration notice timing (NTA, 15 October 2026), not a guarantee.

Stage	What happens	Timing
Incorporation registered	The first taxable period begins; capital decides whether the company starts as taxable	Date of establishment
Corporate number designated	The NTA assigns the corporate number	After the incorporation registration
Notification of establishment	Filed with the tax office with the other post-incorporation notifications	Soon after incorporation
e-Tax start notification	The company receives its user identification number for e-Tax	Before filing online
Registration application filed	Filed with the first-day option selected	No later than the last day of the first taxable period
NTA review	The tax office checks the application and enters the company in the register	About 2 months (e-Tax) or 2.5 months (paper)
Registration notice	The T-number and registration date are sent, to the e-Tax message box if electronic delivery was chosen	On completion of review
Public listing	Company appears on the Publication Site	After registration

Invoicing before the notice arrives

When registration is backdated, the duty to issue qualified invoices runs from the first day of the period, but the company has no number to print until the notice comes. The NTA's invoice system Q&A (question 37) suggests three approaches: warn customers in advance and issue qualified invoices after the notice; issue invoices without a number and reissue them; or issue them without a number and later send the number in a document or email linked to those invoices. A reissued invoice must contain every item the qualified invoice system requires. On the buyer side, the same Q&A lets a buyer that confirmed in advance that the seller will be registered claim credit on an invoice without a number, provided it keeps the qualified invoice or number notice sent later.

Registration Backdated to the Date of Establishment

Registration from the date of establishment is a special rule for newly established companies, and it applies only if the application is filed within the first taxable period.

The NTA sets out the rule in its invoice system Q&A, question 11 (revised April 2025), based on Article 70-4 of the Consumption Tax Act Enforcement Order. It takes effect once the tax office enters the company in the register. The deadline is strict: the Q&A says the application must be submitted by the last day of the period itself, even when that day is a weekend, a public holiday or 29, 30 or 31 December. A common slip is to diary the corporate tax return due date, which falls after the year end, instead of the year end itself.

Which forms go in depends on whether the subsidiary is taxable from the start. Under the Consumption Tax Act, a company with capital of JPY 10 million or more at incorporation is taxable from its first day and needs only the registration application (登録申請書, toroku shinseisho). A smaller subsidiary may also be taxable from day one, because a new subsidiary of a large group is not exempt when it meets the group test. An exempt company would normally also file the Report on the Selection of Taxable Proprietor Status (消費税課税事業者選択届出書, shohizei kazei jigyosha sentaku todokedesho), but a transitional measure for taxable periods that include any day in the six years from 1 October 2023 (ending 30 September of Reiwa 11, 令和11年) lets it register and backdate without that report. The measure is in Supplementary Provisions Article 44(4) of the 2016 Amending Act and is set out in the NTA's invoice Q&A question 7. The price: it cannot return to exempt status until the end of the taxable period containing the second anniversary of registration (Supplementary Provisions Article 44(5)), and it must meet the consumption tax filing and payment deadlines.

Subsidiary's position	What to file	Deadline	Registered from
Capital of JPY 10 million or more at incorporation (Consumption Tax Act, Article 12-2)	Registration application, first-day option selected	Last day of the first taxable period	Date of establishment
Taxable from day one under the large-group rule	Registration application, first-day option selected	Last day of the first taxable period	Date of establishment
Exempt at incorporation, wants registration from day one	Registration application, first-day option selected; no selection report (transitional measure)	Last day of the first taxable period	Date of establishment
Exempt, wants registration part way through a period (transitional measure)	Registration application with a desired registration date	At least 15 days before the desired date (Q&A question 7)	The desired registration date
Taxable, misses the first-period deadline	Ordinary registration application	None	The date the tax office registers the company
Exempt, wants registration from the first day of a later period after the transitional measure ends	Selection report plus registration application	Selection report by the last day of the preceding period; registration application at least 15 days before the first day of the period (Consumption Tax Act Article 57-2(2), Enforcement Order Article 70-2)	First day of that taxable period

The T-Number for a New Subsidiary

A new subsidiary's T-number is the letter T followed by its 13-digit corporate number, and customers check it against the registered name on the NTA Publication Site.

The NTA's English version of the Application for Registration as a Qualified Invoice Issuer and its filing guidelines state the format and list what is made public for a corporation: its name, the location of its head office, the registration number and the date of registration. The Qualified Invoice Issuer Publication Site (公表サイト, kohyo saito) is in Japanese only and offers a Web-API and bulk downloads for checking whole supplier lists. The listing shows the corporate name as entered in the commercial register (in commonly used characters), which may differ from the group brand, so send customers the T-number together with the registered corporate name.

Why Japanese Customers Ask for the T-Number Before Signing

Japanese customers ask for the T-number because their input tax credit depends on it: without a qualified invoice they credit only part of the tax.

For purchases from unregistered suppliers, the NTA's summary of the FY2026 tax reform to the invoice system sets a transitional deemed credit of 70% for two years from October 2026, 50% for the two years after that, 30% for one further year, and nothing once that five-year schedule ends.

The question arrives on a supplier registration form or in the contract, where the customer asks for the registration number and a promise to stay registered. Invoices must carry the T-number whether they come from the group ERP or local software; see accounting software under the qualified invoice system.

Filing the Registration Application Through e-Tax

A new subsidiary files the standard e-Tax application with the newly opened business option ticked, and needs a signing certificate it can obtain.

Qualified invoice registration via e-Tax otherwise follows the general steps. For a new subsidiary:

1. Select the registration date. Choose registration from the first day of the taxable period and enter the date of incorporation as that first day.
2. Arrange the electronic signature. A corporation's electronic certificate is issued to its representative. A representative director who has never been resident in Japan has no My Number Card, so check the accepted certificates early, authorise a director or employee by electronic power of attorney (電子委任状, denshi ininjo), or let a licensed tax accountant (税理士, zeirishi) file and receive the notice.

FAQ

Must a change of company name or head office address be reported after registration?

Under Consumption Tax Act Article 57-2(8), a registered issuer files a notification of change in registered matters (登録事項変更届出書, toroku jiko henko todokedesho) promptly after the change, according to the NTA's filing guidelines for the form. A corporation that reports the change on its notification of change to the tax office (異動届出書, ido todokedesho) need not file it separately.

Does a subsidiary that only bills its overseas parent need to register?

Registration happens only on application under Article 57-2 of the Consumption Tax Act, and the duty to issue qualified invoices applies only when the customer is a taxable business in Japan, according to the NTA's Taxation Answer No. 6498, Invoice System (FY2026). A subsidiary whose only customer is a parent outside the Japanese consumption tax system has no customer asking for a T-number, so the question is whether Japanese customers are planned. Charges in the other direction, from HQ to the subsidiary, follow the reverse charge rules for intercompany HQ charges.

Must the subsidiary issue a qualified return invoice for discounts and refunds?

A registered issuer that grants a customer a refund, discount or rebate on a sale must give that customer a qualified return invoice (適格返還請求書, tekikaku henkan seikyusho) showing the prescribed details, according to the NTA's Taxation Answer No. 6359, Adjustment of Tax for Discounts, Returns and Rebates (FY2026). The duty is waived in certain cases, such as when the amount returned is under JPY 10,000 including tax.

Can a subsidiary cancel its qualified invoice issuer registration?

It can, by filing a Notification of Request for Cancellation of the Registration as a Qualified Invoice Issuer under Consumption Tax Act Article 57-2(10)(i). Filed at least 15 days before the first day of the next taxable period, it ends the registration from that day; filed later, it takes effect one period later.

Working with AQ Partners. Our Tokyo team provides qualified invoice issuer registration, customer invoicing administration and accounting software setup for foreign companies operating in Japan. Book a consultation to review your subsidiary's registration timeline.