Japan Submits Draft Pillar Two Law to Parliament

On February 3 and 6, 2023, the Ministry of Finance published the “Bill for the Partial Revision of the Income Tax Act”. This includes the proposed implementation of the Pillar Two GloBE rules from April 1, 2024. The bill is subject to parliamentary approval.

[UPDATE: Japan’s Bill for the Partial Revision of the Income Tax Act was approved enacted by the Japanese Parliament on March 28, 2023. See: Japan’s Global Minimum Tax Law Is Enacted.]

The following materials were released:

○ Draft Law: https://www.mof.go.jp/about_mof/bills/211diet/st050203h.pdf
○ Overview of the Bill: https://www.mof.go.jp/about_mof/bills/211diet/st050203g.pdf
○ Outline of the Bill: https://www.mof.go.jp/about_mof/bills/211diet/st050203y.pdf
○ Reason for the Bill: https://www.mof.go.jp/about_mof/bills/211diet/st050203r.pdf

The Bill includes a new Chapter 2 in the Corporate Tax Act to provide for the global minimum tax. This includes:

Section 1 General Provisions (Article 82-Article 82-3)
Section 2 Tax Base (Article 82-4)
Section 3 Tax Amount Calculation (Article 82-5)
Section 4 Declaration and Payment, etc. (Article 82-6-Article 82-10)

Sign into your account to access this analysis

Not a Subscriber?

If you haven’t got a subscription you can join up below.

Already a Subscriber?

Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

Cookie	Duration	Description
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Australia Issues Rules for the Detailed Application of the Global Minimum Tax

Luxembourg Parliament Approves Global Minimum Tax Amendment Law for OECD Administrative Guidance

Isle of Man Issues the Cessation Form for Pillar 2 Domestic Top-Up Tax

Kenya Enacts a Domestic Minimum Tax in its Tax Laws (Amendment) Act, 2024