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Sourcing the Japanese Pillar Two Law to the OECD Model Rules

 
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.
 
This includes the implementation of the Pillar Two GloBE rules for Accounting Periods beginning on or after April 1, 2024.
 
In the table below we source all of the global minimum tax provisions in the Japanese law back to the OECD Model Rules (or other guidance, eg the Administrative Guidance). We also includes notes where there are differences from the provisions in the Model Rules.
 
It should be noted that the sourcing table below makes it clear that there are significant gaps in the implementation and detailed Ministerial Ordinances will be essential to effective implementation. 

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Lee Hadnum

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.

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