National Tax Agency issued updated Q&A guidance on the Pillar 2 global minimum tax for fiscal years starting 1 April 2024.
Japan’s National Tax Agency (NTA) updated its Q&A guidance, in October 2025, on the Pillar 2 global minimum tax for fiscal years starting 1 April 2024.
The guidance provides a detailed Question and Answer (Q&A) framework on the corporate tax related to International Minimum Taxable Income, a system introduced under the 2023 Tax Reform.
It explains how domestic corporations should calculate and apply the minimum taxable income for fiscal years from 1 April 2024 to 31 March 2025, while also clarifying key terms such as Model Rules and BEPS Inclusive Framework concepts.
The document covers complex calculations, including defining the Enterprise Group, determining Individual Calculation Income (with adjustments for items such as foreign exchange differences and capital gains/losses), and computing the final International Minimum Taxable Income using attribution ratios across various corporate structures.
