Japan has issued three pieces of legislation to implement the Pillar Two GloBE Rules.
On, March 31, 2023, Act No. 3/2023 revised the Income Tax Act to provide for the high-level GloBE rules.
This was then followed with two further pieces of legislation:
– On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law was published in the Official Gazette.
– On June 30, 2023, Japan’s Ministry of Finance issued Ministry of Finance Ordinance No. 47 of 2023 amending the Enforcement Regulations of the Corporation Tax Act.
The Cabinet Order of the Corporation Tax Law delegates many of the detailed aspects to a Ministerial Ordinance.
As such, the Ministerial Ordinance ‘fleshes out’ a lot of the detailed application of the GloBE rules in Japan by inserting Articles 38-2 to 38-48 in the Enforcement Regulations of the Corporation Tax Act.
The Ordinance provides:
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