An article by article analysis that sources all of the articles of the Japanese Pillar Two Law, Cabinet Order and Ministerial Ordinance back to the OECD Model Rules, including notes where there are differences from the provisions in the Model Rules.

Japan has issued three pieces of legislation to implement the Pillar Two GloBE Rules. In this article we look at the final piece (to date) in Japan’s GloBE law – the Ministerial Ordinance.

Cabinet Order No. 208/2023 accompanies the previous GloBE law and provides further detail on many aspects of the GloBE rules.

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 for Pillar 2 purposes.

On June 16, 2023, Cabinet Order No. 208 was published in Japan’s Official Gazette. This provides much more detail on various aspects of the Pillar Two GloBE rules in Japan from April 1, 2024.

On June 16, 2023, a Cabinet Order to Partially Amend the Enforcement Order of the Corporation Tax Law for Pillar 2 was published in the Official Gazette.

The “Act for the Partial Revision of the Income Tax Act” was promulgated in Special Issue No. 25 of the Official Gazette on Friday, March 31, as Act No. 3/2023.

On March 28, 2023, Japan enacted the second domestic law to give effect to the Pillar Two GloBE rules from April 1, 2024. 

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