GloBE Country Guide: Japan


Status Enacted
LawBill 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 DateAccounting Periods Beginning On or After April 1, 2024.
IIRYes (2024).
Filing DeadlinesStandard.
Safe HarboursTransitional CbCR Safe Harbour.

  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties
  7. Sourcing Japans Pillar 2 Law to the OECD Model Rules

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