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Japan: Corporate and Tax Quarterly Update – July 2023

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In brief

In this issue, we focus on the FY2023 Tax Reform Enforcement Order and Enforcement Regulations and the Guidelines on Respecting Human Rights in Responsible Supply Chains.

On the tax side, the Cabinet Order Partially Amending the Order for Enforcement of the Income Tax Act (“Cabinet Order“) and the Ministerial Order Partially Amending the Ordinance for Enforcement of the Income Tax Act in relation to the 2023 Tax Reforms (“Ministerial Order“) were published in a special extra (No. 25) of the Official Gazette dated 31 March 2023.

On the corporate side, in April 2023, the Ministry of Economy, Trade and Industry of Japan published the “Reference Material on Practical Approaches Enabling Business Enterprises to Respect Human Rights in Responsible Supply Chains” (“Reference Material“). The Reference Material provides in-depth explanations and examples of considerations and steps that business enterprises may undertake, including “formulating a human rights policy” and “identifying and assessing adverse impacts on human rights”.

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Masahiro Inaba is a partner with the Firm’s Corporate/Mergers & Acquisitions Practice Group in Tokyo. Mr. Inaba regularly assists clients in general corporate law matters. He is a member of the Tokyo Bar Association.

Author

Masao Katsuyama is a partner of the Firm’s Corporate / Mergers & Acquisitions Practice Group in Tokyo. Mr. Katsuyama worked in the Firm's Bangkok office from May 2012 to May 2014. He assisted many Japanese companies with investments in Thailand and other Southeast Asian countries.

Author

Ryutaro Oka has significant experience in the finance, trade, energy and manufacturing industries, where he has developed and maintained good client relationships. He regularly advises on complex international tax issues, working extensively with colleagues in the US, UK, Netherlands, China, Singapore and Thailand. Mr. Oka is a frequent speaker on international tax issues, having been invited to speak on international taxation and cross-border private equity investments at events sponsored by the Association of Taxation Analysis, among others. Prior to joining the Firm in 2006, Mr. Oka was a tax director at Deloitte Touche Tohmatsu's Tokyo office, where he advised on international tax issues. Mr. Oka is fluent in English.

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Akihiro Kawasaki is a member of the Firm's Tax & Transfer Pricing Group in Tokyo. He has a wide range of experience – including HK IPOs, crypto currency issues and tax audits – and is particularly proficient in tax consulting involving complex consolidation and reorganization-related tax concepts as well as anti-CFC rules. Prior to joining the Firm, he worked for a major Japanese tax consulting firm for 13 years, including a four-year assignment in Shanghai.

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Koji Oshima is experienced in international tax and transfer pricing matters. Prior to joining Baker McKenzie in 2008, he worked for Deloitte Touche Tohmatsu.

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Luke Tanner is a member of the Tax & Transfer Pricing group at Baker McKenzie's Tokyo office. Prior to joining the firm, he worked at a Big Four accounting firm in Japan and Australia, where he provided tax and transfer pricing services to multinational clients.

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Corey is a member of the Firm’s Tax & Transfer Pricing Group in Tokyo.

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