Murata Sogo Tax Accounting Office, specializing in inheritance and international taxation, is located in Miyakojima Ward, Osaka City.
This article summarizes the documents required for foreign corporations to file corporate tax returns in Japan.

1. Corporate Tax Returns for Foreign Corporations

Foreign corporations with a permanent establishment (hereinafter referred to as “PE”) in Japan are required to file corporate tax returns within two months from the end of each fiscal year. Even foreign corporations without a PE in Japan are required to file corporate tax returns if they have domestic-source income in Japan.  

2. What's PE?  

The definition of a PE under the Corporate Tax Act is as follows. However, if there are different provisions in tax treaties with other countries, those provisions shall apply.

① A place in Japan where the management of a business is conducted, including branches, offices, factories, workshops, mines, or other locations for the extraction of natural resources, or other specific locations where business activities are conducted.  

② A place in Japan where construction, installation, or related supervisory services are provided for more than one year.  

3. What documents Must be Attached on a Corporate Tax Return?

The documents to be attached when a foreign corporation files a final tax return are specified in Article 61-5 of the Corporate Tax Law Enforcement Regulations. Specifically, they are divided into cases where a PE exists and cases where it does not, and the contents are as follows.  

① When a PE exists  

・Balance sheet, income statement  

・Statement of changes in equity  

・Schedule of account items (only the portion related to domestic-source income)

• (If applicable) Merger agreements, division agreements, etc., related to organizational restructuring  

• (If applicable) Detailed statements regarding the types of assets or liabilities transferred from the merged entity, divided entity, etc., and other major matters related to the organizational restructuring  

• Balance sheet, income statement, and statement of changes in equity related to domestic-source income

・Business overview statement

・(If applicable) In cases where the business involves transportation by ship or aircraft, and the income generated from such business constitutes international transportation income attributable to operations conducted within Japan, a detailed statement specifying the amount of income and the basis for calculation, etc.

② In cases where there is no PE

・Balance sheet, income statement

・Statement of changes in shareholders' equity

• Statement of Account Details (only the portion related to domestic-source income)  

• (If applicable) Merger agreements, division agreements, etc., related to organizational restructuring  

• (If applicable) Detailed statement regarding the types of assets or liabilities transferred from the merged entity, divided entity, etc., and other major matters related to the organizational restructuring

• Balance sheet, income statement, and account detail statement related to domestic source income

• Business overview statement

This summary outlines the required attachments for corporate tax returns filed by foreign corporations. If you have any questions or inquiries regarding the final tax return for foreign corporations, please contact us via the inquiry form.