| Status | Enacted |
| Law | On April 26, 2024, the Japanese National Tax Agency issued detailed explanatory notes on the application of Japan’s Pillar Two law/ordinance. On April 12, 2024, the “Ministerial Ordinance to Partially Amend the Enforcement Regulations of the Corporation Tax Law” was published in the Official Gazette. This includes tax return forms (in Japanese) for reporting top-up tax under Japan’s Income Inclusion Rule. The top up forms are included in Appendix 20 of the Enforcement Regulations to the Corporation Tax Law, and can be viewed at: Top-up tax forms. Bill for the Partial Revision of the Income Tax Act of February 6, 2023 (Approved by Parliament on March 28, 2023) and published in the Official Gazette on Friday, March 31, as Act No. 3/2023. 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. On September 29, 2023, the National Tax Agency published the “Partial Revision of the Basic Circular on Corporate Tax” which provides some administrative guidance on various aspects of Japan’s GloBE law. On October 20, 2023, the Japanese Ministry of Finance released its technical explanation of the Japanese Global Minimum Tax Laws and Regulations. On December 25, 2023, Japan’s National Tax Agency issued Frequently Asked Questions on the Japanese Income Inclusion Rule. |
| Effective Date | Accounting Periods Beginning On or After April 1, 2024. |
| IIR | Yes (2024). |
| UTPR | No. |
| QDMTT | No. |
| Filing Deadlines | Standard. |
| Safe Harbours | Transitional CbC Safe Harbour, QDMTT Safe Harbour, NMCE Simplified Calculations |
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