Recently, Japan has introduced notification requirements related to Country-by-Country Reporting (CbCR) in line with the Organization for Economic Co-operation and Development (OECD) action plan on Base Erosion and Profit Shifting (BEPS) Action 13.
The details of the requirements are summarised below:
- The notification requirements are for groups with an entity in Japan (Japanese and overseas headquartered companies) that is part of a group that will be required to create a CbCR per the Japanese requirements.
- Japan has followed the suggested deadline within Article 3, of the last day of the reporting fiscal year (RFY) of the multinational group.
- The notification requirement relates to RFYs commencing from or after 1 April 2016. Companies with years ending 31 March 2017 will be first impacted by the requirement. For companies with a RFY ending in December, the first deadline will be 31 December 2017.
- The notification requires basic information including details of the ultimate parent entity, surrogate parent entity, and entities in Japan. The form also covers the instances when there are multiple entities in Japan and one entity will submit on behalf of the others.
- The notification should be submitted electronically via E-tax (the same system as other items such as the master file and tax return).
The notification also includes an unofficial translation of the forms. It is important to note that the original Japanese forms should be submitted, and not English versions of the form.