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グループ内取引等に係る税制・Intra Group Transactions Tax System by Mind Map: グループ内取引等に係る税制・Intra Group Transactions Tax System
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グループ内取引等に係る税制・Intra Group Transactions Tax System

System pre reform

transactions within a consolidated tax group

qualified corporate reorganisations

Scope issues

Complete controlling relationship

criteria for assets subject to the IGTTS

conditions for transferor and transferee company

special cases

transfer or assets subject to adjustment on qualified reorganisation of receiving company

liquidation of tranferring company on a qualified merger

non qualified mergers

subsequent recognition

loss of Complete Controlling Relationship

simplified recognition method

subsquent recognition of GOT or LOT for GLOT Adjusted Assets on commencement or entry into Japanese consolidated tax group

reasons arising at the Transferee for subsequent recognition of GOT or GOL for GLOT Adjusted Assets (recognised by Transferor)

procedural issues

notification obligations

effect

deferral of Gain on Transfer or Loss on Transfer

calculation of Gain on Transfer or Loss on Transfer

required sundry changes

abolishment of qualified post incorporation transactions