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Policy Proposals  Business Law Proposal for Fiscal 2016 Tax System Reforms

September 8, 2015


Backed by Abenomics, improvements are being seen in ordinary profits and capital spending, in wages and in corporate and income tax revenues. To further accelerate reforms, the business community will also work on measures proactively to create a positive economic growth cycle through private sector-led innovations.

From this standpoint, the following specific measures shall be taken:

1. Consumption tax

  1. (1) While ensuring countermeasures for declines in demand and reactionary falls, the consumption tax rate should be steadily raised to 10% in April 2017 as scheduled.

  2. (2) We oppose the introduction of multiple tax rates from standpoints such as the difficulty in drawing the line between items subject to varying rates and the increase in the administrative workload of tax collectors and taxpayers.

2. Continuation of comprehensive reforms to corporate taxation

  1. (1) It is important to work on further reducing the effective corporate tax rate and realize a rate below 30% at the earliest possible time in order to raise Japan's locational competitiveness, to promote direct investments in Japan and to work on revitalizing the Japanese economy, based on the content of the Basic Policy on Economic and Fiscal Management and Reform and the Japan Revitalization Strategy. On this basis, the tax rate should be lowered in the future to 25%, which would be on a par with the average of member states of the Organisation for Economic Co-operation and Development and with neighboring Asian countries.

  2. (2) As research and development is a lifeline for our country as an innovation-oriented nation, it is essential to maintain and expand the tax system promoting research and development. Discussions based on the idea that we have to choose only one option between an effective corporate tax rate and a research and development taxation system are therefore inappropriate.

3. International taxation

  1. (1) National legislation based on the achievements of the BEPS (Base Erosion and Profit Shifting) Project:

    1. [1] Concerning putting domestic legislation in place in relation to transfer pricing documentation (Action 13), it is essential to first clarify the definition of intangible assets, take fully into consideration the situation such as the administrative workload for business operators to compile reports, and secure a sufficient preparatory period. In addition, concerning the taxation method related to hard-to-value intangibles (Action 8), it is necessary to continue considering the matter carefully, including clarifying applicable conditions, in order to avoid tax imposition based on simple hindsight.
    2. [2] Concerning CFC (controlled foreign company) taxation (Action 3), it is necessary to address individual issues, including how to handle matters such as the scheduled reduction of the corporate tax rate in the United Kingdom and income derived from aircraft leasing businesses, such as operated in Ireland, as soon as possible. At the same time, we should carefully consider whether or not a drastic review of the system is necessary, including comparing the merits and demerits of the existing Japanese system.
    3. [3] On the interest deductions and other financial payments (Action 4), it is necessary to establish a reasonable fixed ratio regarding interest deductions based on the company's situation and fully consider the company's cash management capabilities.
  2. (2) Tax convention

    1. [1] In relation to BEPS, it is important to exclude excessively strict limitations on benefits (LOB) provision and to secure stability in implementation by various countries in Action 6, to compile a clear guideline concerning PE (permanent establishment) status and ensure consistent implementation in Action 7, and to improve mutual agreement procedures (Action 14) and share the outcome of that improvement among nations (Action 15).
    2. [2] Tax treaties with China, India, Thailand, Indonesia, Vietnam and others should be revised, while negotiations toward concluding tax treaties with Taiwan, Myanmar, Chile, Argentina and others should be promoted.

Business Law