Cross-border Tax Talks

Pillar Two: A Japanese perspective

Apr 5, 2023

37:41

AI Chapters

Episode notes

Introduction

3min

How to Reassess the Tax Operations of Japanese Multinationals

2min

How to Implement the 2023 Tax Reform in Japan

2min

The OECD's Safe Harbor Guidance on Tax Reform

2min

The Income Inclusion Rule and the Under Tax Payment Rules

2min

The Transitional Safe Harbors for Taxpayers

2min

The April 1st Deadline for Japan's IIR

2min

The Japan-Iar Guide to the Global Information Return

2min

The Concerns of Japanese Taxpayers About Information Sharing

3min

10.

The Japan CFC Regime and the Pillar to It

2min

11.

The Japan CFC and the US CFC Regime

2min

12.

QDMTT and CFC Income Pickup in Japan

2min

13.

The Complexity of QDMTT

2min

14.

The Importance of Operational Readyness in Tax Reform

2min

15.

The Importance of Interaction in the Tax Function

4min

16.

The Importance of Inbound Investment in Japan

2min

17.

The Tax Controversy in Japan

3min

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Shin Yamaguchi at PwC’s 2023 International Tax Conference. Shin is a Tokyo-based International Tax Partner, where he leads PwC Japan’s Inbound Tax Practice. Doug and Shin discuss Japan’s latest tax developments, focusing on the Pillar Two rules (of course!), specifically, UTPR, IIR, Safe Harbours, QDMTT, the GloBE Information Return and effective dates. They also discuss the Japanese legislative process.Since the recording of this podcast Japan has enacted their 2023 Tax Reform Bill which includes the Pillar Two Income Inclusion Rule which applies on or after April 1, 2024.