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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

deferral of gain or loss until recognition event (transfer out of group, abandonment etc)

qualified corporate reorganisations

Scope issues

Complete controlling relationship

criteria for assets subject to the IGTTS

Fixed Assets

Land

Rights Over Land, excluding Fixed Assets

Marketable Securities, excluding Trading Securities of the transferor..., excluding Marketable Securities that would be treated as Trading Securities for the Transferee...

Monetary Assets

Deferred Assets

de-minimus exclusion, assets where Book Value immediately prior to transfer <JPY10m, netting and classification rules for applying de-minimus exclusion, Monetary Assets - apply to each creditor, Depreciable Assets, buildings - each building, referring to definition in real estate law, plan and machinery - by machine, other Depreciable Assets - apply similar logic, Land and ROLs - each plot, Marketable Securities - by type (銘柄), other assets - by unit normally transacted in

conditions for transferor and transferee company

transferor must be..., Ordinary Japanese Company, Defined Japanese Co-operative Association

transferee must be..., Ordinary Japanese Company, Defined Japanese Co-operative Association

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

gain or loss is recognised by the Transferor co in the Tax Accounting Year in which the day on which Complete Controlling Relationship is lost with the Transferee company except..., exceptions - transfer further to the dissolution of the Transferor or Transferee on their Tax Qualified Merger provided the Merger Successor Company maintains Complete Controlling Relationship with the remaining Transferor or Transferee

simplified recognition method

where certain conditions are met, recognition for Depreciable Assets and Deferred Assets can apply, based on the number of months of depreciation

attached detailed calculation must be attached to the tax return

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

de-minimus exception - remaining unrealised GOT, LOT is less than JPY10m

GOT or LOT on certain GLOT Adjusted Assets received prior to merger or on another group member leaving the group

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

where the following circumstances arise, further Transfer of GLOT Adjusted Assets transfers, disposals (e.g. where assets are no longer used), settlement of debts or other similar circumstances, transfer to a Corporate Split Successor Company in a Tax Qualified Corporate Split, on conversion of the Transferee Company to a Public Purpose Company

when a revaluation of assets is taxable further to certain laws relating to corporate insolvency or rehabilitation

for Depreciable Assets, corresponding to the depreciation of the asset concerned by the transferee company

for Deferred Assets, corresponding to the amortisation of the asset concerned in the hands of the transferee company

for assets subject to tax deductible impairment (further to CTL Art 33 etc) at the time of such tax deductible impairment

for Marketable Securities, where MS of the same type were already owned by the Transferee, proportionate to the sale of the numbers of securities concerned

for securities subject to amortisation or accumulation, proportionate to the months remaining to repayment of the securities concerned

for assets subject to revaluation to market value at the time of commencement of a consolidated tax group, at the time of such commencement

procedural issues

notification obligations

effect

deferral of Gain on Transfer or Loss on Transfer

Transferor company may recognise gain but then include a corresponding deductible loss on qualifying transactions (or vice versa for losses)

calculation of Gain on Transfer or Loss on Transfer

required sundry changes

abolishment of qualified post incorporation transactions