Sourcing the Japanese Pillar Two Law, Cabinet Order and Ministerial Ordinance 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.

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.

In the table below we source all of the global minimum tax provisions in the Japanese :aw, Cabinet Order and Ministerial Ordinance 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.

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