Webinar series: Japan's new tax rules and other tax challenges for Japanese multinational corporations (English language)

05 September 2018
11:00 - 11:45 CEST
Webinar  -  On demand

Like in the Netherlands, and many other OECD countries, Japan has introduced various measures in the last few years to combat perceived tax avoidance by multinational enterprises.  In particular Japan has put the overseas structures and activities of its global corporations under greater scrutiny.

One of such measures is the recent fundamental revision of Japan's anti-tax haven rules (also referred to as "Controlled Foreign Companies" or "CFC" rules).  The updated rules more closely reflect the OECD's recommendations from its comprehensive Base Erosion and Profit Shifting (BEPS) project.

In order to stay compliant with the new CFC rules, Japanese multinational corporations and their foreign subsidiaries may need to revisit their group structure. Should they fail to respond adequately, then income of such foreign subsidiaries might become taxable in Japan. This holds especially true for structures involving overseas holding and/or financing companies, or other types of SPCs, that do not (predominantly) conduct active business activities. For these companies, having a sufficient level of local substance and/or management and control is becoming increasingly important.

On top of the changes to the CFC rules, Japanese multinational corporations are facing a rapidly changing tax landscape in the Netherlands and elsewhere in the world, with substance requirements being enhanced and measures aimed to counter treaty shopping being introduced.


 Watch on demand here 


In this webinar we team up with PwC Tax Japan and the Netherlands and provide our insights on:

  • the main aspects of the recent Japanese CFC reforms; 
  • the impact of recent Dutch tax developments as well as the changing international tax landscape (for Japanese corporations); and
  • how to respond adequately to these changes from a global tax compliance point of view.

TMF Group is the organizer and jointly presenting with PwC. 

This webinar is focused on Japanese MNCs and their overseas subsidiaries (individuals responsible for corporate tax governance).

Webinar language: English

Our speakers:

  • Ken Leong │ Tax advisor at PwC Tax Japan
    Ken Leong has over 20 years of experience in PwC's international tax practice, of which he has worked 17 years in PwC's Tokyo office.  During his career, he has advised many Japanese multinational companies on outbound investment matters, with extensive knowledge of Japan's controlled foreign company rules.
  • Jorg van Leeuwen │ Tax advisor at PwC Tax Japan
    Jorg van Leeuwen advises on international, Dutch and Japanese tax matters with a particular focus on international tax compliance and planning, M&A transactions, and corporate reorganisations. He has (co-)authored several articles which have been published in professional tax journals.
  • Pieter Janson │ Tax advisor – at PwC Netherlands
    Pieter Janson is a Director in PwC Netherlands' international tax services practice where he is responsible for providing Dutch tax services to large Japanese multinational companies.  Pieter was seconded to PwC's Tokyo office from 2012 until 2014.
  • Toru Ozawa │Commercial Director TMF Netherlands B.V.
    Toru Ozawa is based in Tokyo as Commercial Director (Japan) TMF Netherlands B.V. to introduce its wide scope of services to the Japanese corporate, investor and advisor communities.  Bringing his experience in understanding Japanese institutions, having worked in its financial sector for 30 years in Japan and overseas, Toru joined TMF in 2016.

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