Japan Outlines 2010 Tax Reforms

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Executive Summary

A new intra-group transaction regime will be introduced under which gain or loss from transfers of certain assets between domestic companies which are 100% group companies will be deferred until the asset is transferred outside the corporate group. These assets would include fixed assets, land, monetary claims, securities and deferred assets (but not securities held for sale or assets with book values of less than ?10 million ($110,000). Furthermore, the tax treatment of corporate donations between 100% group companies will be changed, with the company making the donation being denied a deduction completely, while the company receiving the donation would be permitted to exclude the gain.

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