Japan Tax Update Tax Reform Proposal. Issue 83, January 2013

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1 Japan Tax Update 2013 Tax Reform Proposal Issue 83, January 2013 The 2013 tax reform proposal submitted by the Cabinet Office s Tax Commission, known as Taiko ( 2013 Tax Reform Proposal ), was released on January 29, 2013 upon approval by the Cabinet. The proposed tax law changes will be submitted to the Diet during February 2013 for consideration. In the 2013 Tax Reform Proposal, a number of tax s are proposed to stimulate domestic investment and to increase employment by corporations. In addition, proposed amendments to the individual income and inheritance tax laws are included which relate to previous legislation passed on August 22, 2012 (i.e., certain social security reforms) which will take effect on April 1, In addition, under the 2013 Tax Reform Proposal existing R&D s and employment promotion s are enhanced by relaxing requirements and increasing the associated tax benefits. The 2013 Tax Reform Proposal also includes increases in individual income tax rates for the highest tax bracket and reduces certain inheritance tax deductions (for more detail on these provisions, please see our Financial Services Tax News, Estate Taxation Highlights and International Assignment Services Alert issued in January 2013).

2 1. Corporate Tax (1) New domestic and SME investment s A new investment tax is proposed which will be applicable to new domestic investments. The Incentive for New Investment into Production Facilities will be applicable to any industry which invests in new production facilities. In addition, a new investment will apply to small to medium sized enterprises ( SMEs ) which invest in equipment and furnishings pursuant to certain facility remodelling. The SME tax will be granted to an SME engaged in the distribution, retailing, service, and/or agriculture business. For both s, only corporations filing a blue form are eligible. In addition, the proposed s are effective for tax years beginning on or after April 1, 2013 through March 31, New for investment in production facilities New for investment in equipment and furnishings as part of a remodelling project Incentive conditions The gross amount of new domestic manufacturing production facilities placed in service during the year by a corporate taxpayer exceeds a) and b). a) Gross depreciation expense (including special reserve) for accounting purposes b)110% of prior year s total acquisition cost for domestic production facilities An SME engaged in the distribution, retailing, service, or agriculture industry acquires and places in service furnishings (600,000 yen or more per unit) and/or other equipment (300,000 yen or more per unit) as part of a remodelling project pursuant to professional management improvement advice. Credit or deduction allowed Corporations can elect special accelerated depreciation (30% of the acquisition cost of machinery and equipment used in manufacturing production facilities) or a tax credit (3% of the acquisition cost of machinery and equipment used in manufacturing production facilities). The credit is limited to 20% of the corporate tax liability before the credit. For a large corporation, such benefit is for national tax purposes only. For an SME, the benefit is available for national and inhabitants tax purposes. Based on the language of the 2013 Tax Reform Proposal, it appears that the depreciation benefit (but perhaps not the credit) may be available for enterprise tax purposes as well. Special depreciation (30% of the acquisition cost). For an SME with capital of 30 million yen or less, either special accelerated depreciation or a tax credit is allowed by election. The tax credit is 7% of the acquisition cost with a limitation of 20% of corporate tax liability before the credit (excess acquisition cost for credit purposes can be carried over for one year). PwC 2

3 (2) Amendments to the R&D tax Pursuant to the 2012 Tax Reform, the R&D credit limitation (as well as the R&D credit carryover) was lowered from 30% to 20% for tax years commencing on or after April 1, Under the 2013 Tax Reform Proposal, the R&D credit limitation will be increased to 30% for tax years commencing on or after April 1, 2013 through March 31, Further, the scope of eligible R&D expenditures for the Special R&D credit (a credit granted for R&D costs incurred pursuant to certain defined contracts) will be expanded to include joint R&D other than with the government. All s require the corporation to be a blue form filer. Permanent (gross R&D cost base) R&D tax Gross R&D cost based credit Special R&D cost based credit Gross R&D cost based credit for an SME Summary of the tax Corporation is allowed to a claim a tax credit for a certain percentage of gross R&D costs. Corporation is allowed to claim a tax credit for a certain percentage of gross R&D costs incurred pursuant to certain defined contracts. SME corporation is allowed to claim a tax credit for a certain percentage of gross R&D costs. Limitation of credit A credit against national corporate tax is allowed for the smaller of a) or b). a) up to 12% of the gross R&D cost (rate depends upon average annual sales and whether both gross and special R&D costs are included) b) 20% of corporate tax before credit for a tax year commencing from April 1, 2012 to March 31, 2013 or 30% of corporate tax before credit for a tax year commencing from April 1, 2013 to March 31, Excess R&D cost may be carried over for one year. A credit against national corporate tax is allowed for the smaller of a) or b). a) 12% of the gross R&D cost b) 20% of corporate tax before credit for a tax year commencing from April 1, 2012 to March 31, 2013 or 30% of corporate tax before credit for a tax year commencing from April 1, 2013 to March 31, An additional inhabitants tax credit based of a maximum of 20.7% times the national corporate tax credit is also applicable (rate for Tokyo). Excess R&D cost may be carried over for one year. Temporary (incremental R&D cost base) Incremental R&D cost based credit Corporation is allowed to claim a tax credit for tax years commencing during the period from April 1, 2008 to March 31, The tax credit is allowed in addition to the above gross based credit. A credit against national corporate tax is allowed for the smaller of a) or b). a) the higher of (i) 5% of incremental R&D cost or (ii) R&D costs in excess of 10% of the average sales, times the tax credit ratio (ratio is a mechanical calculation which increases the credit depending upon the relationship between the amount of R&D costs and average annual sales). b) 10% of tax liability before the credit. PwC 3

4 (3) New for increased employment/salary payment Under the 2013 Tax Reform Proposal, a new tax will be introduced to allow an employer corporation to claim a tax credit based on increases in salary payments. The employer corporation is allowed to claim a credit by either Increased employment or employment promotion. To take a credit, the employer corporation must be a blue form filer. Under the 2013 Tax Reform Proposal, the credit will be effective for tax years commencing from April 1, 2013 to March 31, Increased employment Conditions for application A 5% increase in salary paid to domestic employees (Note 1) compared to the prior year s salary (Note 2) and certain other conditions are met. Limitation of credit The national tax credit is equal to 10% of the increased salary amount with a limitation of 10% (20% in case of SME) of the tax liability before the credit (for an SME, an additional inhabitants tax credit equal to 20.7% of the national tax credit is also applicable). (Note 1) Those employed by a business entity located in Japan other than directors and related persons. (Note 2) The increased percentage is calculated based upon tax deductible salary payments made to domestic employees in the applicable year compared to a base year. The base year is defined as the year immediately prior to the first applicable year of this regime (i.e., the first tax year commences on or after April 1, 2013). (4) Amendments to the employment promotion Under the 2011 Tax Reform, an employment promotion was introduced which provided for tax credits. Pursuant to the 2013 Tax Reform Proposal, the employment promotion tax credit amount will be increased and the eligible employees for the will be reviewed. To take a credit, the employer corporation must be a blue form filer. The new rules will be effective for tax years commencing from April 1, 2013 to March 31, Amendments to employment promotion Conditions for application Increase the number of employees subject to employment insurance by 10% or more and by five people or more (two or more in the case of an SME) from the end of the prior tax year. Limitation of credit The tax credit is equal to the increased number of the employees multiplied by 200,000 yen (400,000 yen after the amendment) with a limitation of 10% (20% in case of SME) of the tax liability before the credit. For an SME, an additional inhabitants tax credit of approximately 20.7% of the national credit is applicable. (5) Other tax s for SMEs Under the 2013 Tax Reform Proposal, the deduction limitation for entertainment expense will be increased from the current 5.4 million yen to 8 million yen. Under certain circumstances, SMEs will be allowed to recognize valuation losses or income and deduct expired losses to offset valuation income or debt forgiveness income. (6) Other corporate tax amendments 1) Deduction of expired loss to offset debt forgiveness income Under current law, if a corporation that is under Civil Rehabilitation Act procedures has income other than debt forgiveness income, such corporation can deduct expired tax loss carryforwards to offset any income earned while under Civil Rehabilitation Act procedures. Under the 2013 Tax Reform Proposal, the deductible expired loss will be limited to 80% of the income other than debt forgiveness income (expired losses can continue to offset 100% of debt forgiveness income). PwC 4

5 2) Amendments to deduction limitations for built-in losses and tax loss carryforwards after a tax qualified merger Currently, the deduction for built-in losses for specified assets transferred and tax loss carryforwards after a tax qualified merger are subject to a number of limitations. The 2013 Tax Reform Proposal provides that such builtin losses and tax loss carryforward provisions will be reviewed to further limit the ability of the merged company to claim such deductions after a merger. The 2013 Tax Reform Proposal would be applicable for built-in losses for specified assets held or tax losses carried forward by a corporation where the merged and merging companies become related parties (i.e., more than a 50% equity relationship) on or after April 1, ) Amendments to the tax basis of a subsidiary company in a tax consolidated group Currently, the tax basis of a subsidiary company in a tax consolidated group is not revised as a result of a share buy-back by the subsidiary company. Under the 2013 Tax Reform Proposal, the tax basis of a subsidiary company shall be revised as a result of a share buy-back by the subsidiary company in a manner similar to if the shares were transferred by the parent company to a third party or other subsidiary company. 4) Amendments to the surtax levied on the undistributed earnings retained by a parent family corporation of tax consolidated group Generally, a parent family corporation (generally a corporation controlled by an individual or family) filing a consolidated tax return is subject to a surtax on undistributed earnings. Under current statutes, a monetary dividend distribution or a tax qualified dividend in kind within consolidated group companies can reduce the amount of undistributed retained earnings for surtax purposes. Under the 2013 Tax Reform Proposal, the amount of tax qualified dividend in kind shall be included as an adjustment for family surtax purposes so that only dividends by the parent company reduce undistributed retained earnings for surtax purposes. 5) Amendments to the individual income tax regime through adoption of a new taxation method of financial income Applicable for interest income received on or after January 1, 2016 by a corporate recipient, only national tax will be withheld at source. Further, with respect to the application of the withholding income tax credit, the entire amount shall be creditable regardless of the holding period. 2. International Tax (1) Amendments to the earnings stripping rules Pursuant to the 2012 Tax Reform, an earnings stripping regime which limits interest deductions was introduced which will take effect from fiscal years beginning on or after April 1, Under the earnings stripping regime, the earnings stripping regime will not apply for the cases listed in the box below. Further, under existing law when both the earnings stripping and previous existing thin capitalization rules apply to limit tax deductions, the tax regime which is to be applied is the regime where the disallowed interest expense is higher. Under the 2013 Tax Reform Proposals, the rules which apply when both the earnings stripping and thin capitalization rules apply shall be reviewed. The earnings stripping rules will not apply if a) or b) is met: a) Net Interest to Related Parties is equal or less than 10 million yen in the fiscal year, or b) The Interest Expense to Related Parties (Note) is 50% or less of the total interest expense in the fiscal year. (Note) Interest expense does not include interest subject to Japanese corporation taxation in the hands of recipient. (2) Amendments to the foreign tax credit regime In the formula for calculating the foreign tax credit limitation ( FTC limitation ), a certain portion of untaxed foreign source income of a corporation is excluded from foreign source income. Currently, if a resident country (the country where the head office is located) of a CFC (a foreign corporation that is subject to the Anti-Tax PwC 5

6 Haven ( CFC ) Rules) does not tax such income, the income of such CFC is treated as untaxed foreign source income. Under the 2013 Tax Reform Proposals, if such income is taxed in a country other than the country of residence, the CFC s income will not be treated as untaxed foreign source income. FTC limitation =Corporate income tax (Foreign source income certain portion of untaxed foreign source income) Gross income (3) Amendments to the allowable transfer pricing methods The current Japanese transfer pricing legislation provides for three traditional transactional methods (comparable uncontrolled price method, resell minus method, cost plus method) as well as other methods, i.e., profit split method and transactional net margin method ( TNMM ). As a result of recent amendments to the OECD Guidelines, under the 2013 Tax Reform Proposal the Berry Ratio (a type of TNMM) will become a specifically allowed method. (4) Amendments to the tax treaty application procedures for dividend income Under the 2013 Tax Reform Proposals, the tax treaty application procedures will be simplified for non-resident recipients of dividend income from listed stocks subject to withholding taxation. Currently, non-resident recipients of dividends are required to file an application for each dividend issuer. Under the 2013 Tax Reform Proposal, the procedures will be simplified as following: a) A non-resident recipient who qualifies for tax treaty benefits can file a special treaty application that contains information regarding the non-resident applicant. In the special treaty application, no description of the dividend is required. If certain requirements are met, the special treaty application is effective for three years. b) Non-resident applicants who file the special treaty application should notify the dividend withholding agent prior to each payment date. The notified agent should report to the relevant tax office of the dividend and withholding tax amount in the form of CD or DVD by the 10 th of the following month after the dividend is paid. The above amendments will be applicable for dividends paid on or after January 1, Individual income tax (1) Increase in the tax rate for the highest tax bracket Applicable for income earned in 2015 or onward, the tax rate for the highest tax bracket will be increased from the current 40% to 45%. Income bracket Tax rate (Note) Proposed tax rate Up to 1.95 million yen 5% 3.3 million yen or less 10% 6.95 million yen or less 20% 9 million yen or less 23% 18 million yen or less 33% 40 million yen or less 40% Over 40 million yen 45% (Note) From the income earned on or after January 1, 2013, the Restoration Surtax will be levied at 2.1% of tax liabilities. (2) Amendments to the individual income tax regime by adoption of the new taxation method of financial income Applicable for investment income (from bonds or stocks) earned on or after January 1, 2016, the taxation method will change (details are not yet available). PwC 6

7 4. Indirect taxes (1) Special registration tax relief Under the 2013 Tax Reform Proposals, special relief for registration tax upon transferring title to lands by selling will be extended for another 2 years through March 31, Type of title transfer Taxable basis Normal Tax rate Special relief tax rate Transfer title by selling Value of real estate 2% 1.5% With the amendment to the Law of Corporate Rehabilitation Assisting Institution, special relief for the registration tax will be provided for acquiring title to lands by the Assisting Institution to Reinvigorate Local Economies which purchase credit notes from financial institutions. (2) Special stamp duty relief Under the 2013 Tax Reform Proposal, the current relief from stamp duty levied on the contract for construction or transferring real estate will be extended for another 5 years. In addition, for contracts prepared on or after April 1, 2014, the tax amount will be lowered. Contract amount Current tax Proposed tax Contract for transferring Contract for construction real estate (Note 1) (Note 2) Over 100,000 yen to 500,000 yen Over 1 million yen to 2 million yen JPY 400 JPY 200 Over 500,000 yen to 1 million yen Over 2 million yen to 3 million yen 1, Over 1 million yen to 5 million yen Over 3 million yen to 5 million yen 2,000 1,000 Over 5 million yen to 10 million yen 10,000 5,000 Over 10 million yen to 50 million yen 15,000 10,000 Over 50 million yen to 100 million yen 45,000 30,000 Over 100 million yen to 500 million yen 80,000 60,000 Over 500 million yen to 1 billion yen 180, ,000 Over 1 billion yen to 5 billion yen 360, ,000 Over 5 billion yen 540, ,000 (Note 1) Applicable to the contracts prepared on or before March 31, 2014 (Note 2) Applicable to the contracts prepared between April 1, 2014 and March 31, Amendments to the interest rate for delayed payment of tax and etc. Under the 2013 Tax Reform Proposal, the rate applicable for penalty tax for delayed payment, interest tax or interest accrued on refundable tax will be reviewed for the period on or after January 1, 2014 (assuming that the Special Basic Rate (Note) as defined is lower than 7.3%). Current tax treatment Proposed amendment Penalty tax on For a period 14.6% is applied Special Basic Rate+7.3% p.a. delayed payment For a period 7.3% is applied Special Basic Rate+1% p.a. ( 7.3%) Interest tax Interest rate for inheritance tax/gift tax Interest rate X Special Basic Rate (Interest rate<7.3%) 7.3% Interest tax other than the above Special Basic Rate Interest on refundable tax Special Basic Rate (Note)The rate announced by the Prime Minister of Finance (MOF rate) plus 1%. The MOF rate is computed as an annual average of short term prime rates for the period from October to September in the prior year. PwC 7

8 For more information, please consult your tax representative or contact any of the following members listed below: Zeirishi-Hojin PricewaterhouseCoopers Kasumigaseki Bldg. 15F, 2-5, Kasumigaseki 3-chome, Chiyoda-ku, Tokyo Telephone: , Partner Akemi Kito Yoko Kawasaki Jack Bird Yumiko Arai Managing Director PwC Japan Tax (Zeirishi-Hojin PricewaterhouseCoopers), a PwC member firm, is one of the largest professional tax corporations in Japan with more than 470 people. In addition to tax compliance services our tax professionals are experienced in providing tax consulting advice in all aspects of domestic/international taxation including financial and real estate, transfer pricing, M&A, group reorganisation, global tax planning, and the consolidated tax system to clients in various industries. PwC firms help organisations and individuals create the value they re looking for. We re a network of firms in 158 countries with more than 180,000 people who are committed to delivering quality in assurance, tax and advisory services. Tell us what matters to you and find out more by visiting us at This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors Zeirishi-Hojin PricewaterhouseCoopers. All rights reserved. PwC refers to Zeirishi-Hojin PricewaterhouseCoopers, a member firm in Japan, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details. PwC 8

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