Taxation of Companies Doing Business in Japan

In Japan, companies are required to pay corporate income tax and consumption tax. This obligation applies regardless of whether the shareholders are domestic or foreign investors.

A key issue for foreign companies concerns the scope of taxation. In some countries, corporate tax is imposed only on domestic-source income and not on income generated overseas. In contrast, Japan generally taxes resident companies on their worldwide income, regardless of whether it is earned in Japan or abroad.

If a foreign company conducts business in Japan without incorporating a Japanese subsidiary (for example, by operating through a branch under the Companies Act), it is subject to Japanese tax only on income attributable to its Japanese operations. Specifically, income derived from a branch or factory in Japan that constitutes a permanent establishment is subject to Japanese taxation.

In addition, where the investor’s home country has concluded a tax treaty with Japan, certain taxes may be reduced or exempted. To benefit from such treaty relief, the required procedures prescribed under the applicable treaty must be completed in advance.