Pillar Two: A Japanese perspective
Cross-border Tax Talks
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The Japan CFC Regime and the Pillar to It
Japan CFC regime, it takes an entity-based approach. We look at ETR, effective tax rates and also economic activities. And for example, if your ETR is less than 20% and you lack economic activity, then the pickup is the full income entity-based. In other instances, it might be passive income. So depending on which bucket you end up in, you could be at full or passive.
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