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National tax国税

Corporation Tax Act

法人税法(ほうじんぜいほう)

Japan's national corporation tax: which companies and other bodies pay it, how their taxable income is worked out from their accounts, the rates, and how they file returns and pay.

Text in force since
Promulgated
Articles
262
Amendments on the way
6

What this law does

  • Corporation tax is charged on each business year's income, which is gross profits (益金) less deductible expenses (損金): gross profits are the year's revenue from selling or transferring assets, providing services and other dealings apart from capital transactions, and deductible expenses are the year's cost of sales, its selling, general and administrative expenses whose obligation is fixed by the year's end (depreciation apart), and its losses, all worked out under generally accepted accounting standards unless the Act provides otherwise. A business year (事業年度) is the accounting period set by law or by the corporation's articles, cut into one-year periods if longer; a corporation with none must notify the district director of the tax office () of one within two months of being set up (or of starting a profit-making business, or, for a foreign corporation, of coming to have a permanent establishment or taxable income in Japan), failing which the director designates one (for an association without legal personality, the calendar year applies). Among the Act's adjustments, dividends received from other domestic corporations are left out of gross profits, if the return shows them — all of them for a wholly owned subsidiary, all but related interest for a holding of more than a third, half for a holding of more than 5%, and a fifth for a holding of 5% or less — and so are dividends from a foreign subsidiary (外国子会社), a foreign corporation in which it holds 25% or more, among other conditions a Cabinet Order (政令) sets, apart from an amount for related costs that a Cabinet Order works out.(Art. 21(1), Art. 22(1), Art. 22(2), Art. 22(3), Art. 22(4), Art. 22(5), Art. 13(1), Art. 13(2), Art. 13(3), Art. 13(4), Art. 23(1), Art. 23(4), Art. 23(5), Art. 23(6), Art. 23(7), Art. 13(2)(i), Art. 13(2)(ii), Art. 23-2(1)) (the provisions it rests on)
Read the full overview
  • The rate is 23.2% of income for ordinary corporations (普通法人), for the general incorporated associations and foundations and worker cooperatives listed in Appended Table 2 and public interest incorporated associations and foundations, and for associations without legal personality; other corporations in the public interest (公益法人等) and cooperatives (協同組合等) pay 19%. An ordinary corporation or general incorporated association or foundation, etc. with stated capital of 100 million yen or less, or with none, and any association without legal personality, pays 19% instead on the first 8,000,000 yen of income a year — unless, among others, it is wholly owned by a corporation with capital of 500 million yen or more, or is a mutual insurance company, investment corporation or special purpose company, while members of a group under group tax sharing (通算法人) have a rule of their own. Article 42-3-2 of the Act on Special Measures Concerning Taxation (租税特別措置法) lowers that 19% to 15% — 17% in a business year whose income exceeds 1,000,000,000 yen — for business years beginning from 1 April 2012 to 31 March 2027, but not for group tax sharing members or for those that Act calls excluded businesses (適用除外事業者), and gives the same lower rate on the first 8,000,000 yen to the other corporations in the public interest and to cooperatives apart from those Article 68(1) of that Act names.(Art. 66(1), Art. 66(2), Art. 66(3), Art. 66(5), Art. 66(6), Act on Special Measures Concerning Taxation Art. 42-3-2(1)) (the provisions it rests on)
  • A net operating loss (欠損金額) from any business year that began in the ten years before the current one is deducted from the current year's income, but only up to 50% of that income — in full, though, for small corporations (stated capital of 100 million yen or less, or none, and not wholly owned by a corporation with capital of 500 million yen or more, among other exclusions), corporations in the public interest, cooperatives and associations without legal personality; for a corporation from the start of court reorganization or rehabilitation proceedings (or a similar event the Act or a Cabinet Order (政令) names) until seven years after, unless its shares are listed first; and for an ordinary corporation in its first seven years until its shares are listed or a similar event a Cabinet Order sets, unless it is wholly owned by a large corporation, was set up by a share transfer, or is in a group tax sharing group whose other members are past their own first seven years. The deduction is allowed only if the corporation filed a final return for the year of the loss and every year since and keeps that year's books as a Ministry of Finance Order requires, and a loss from a year for which no blue return (青色申告書) was filed counts only as far as it came from disaster losses to inventory, fixed assets or deferred assets a Cabinet Order sets. A corporation that has filed blue returns continuously, and files the loss year's on time, may instead claim back tax of a business year that began within the year before, but Article 66-12 of the Act on Special Measures Concerning Taxation (租税特別措置法) allows this, for losses of business years ending from 1 April 1992 to 31 March 2028, only to small corporations, corporations in the public interest, cooperatives and associations without legal personality, apart from losses on dissolution and in the other events it lists, and disaster losses.(Art. 57(1), Art. 57(10), Art. 57(11), Art. 57(11)(i), Art. 57(11)(ii), Art. 57(11)(iii), Art. 58(1), Art. 80(1), Art. 80(3), Act on Special Measures Concerning Taxation Art. 66-12(1)) (the provisions it rests on)
  • Pay to a company officer (役員) is deductible only if it is fixed periodic pay given at intervals of a month or less in the same amount at each payment in the year, pay at a set time of a fixed amount of money or number of shares under an arrangement notified in advance to the tax office where the Act requires it, or performance-linked pay to executive officers from a corporation that is not a family company (同族会社) — or is wholly owned by a corporation that is not one — paid to all its executive officers on the same terms and meeting the Act's conditions on objective profit, share-price or sales indicators, a cap, a proper decision and disclosure — retirement pay that is not performance-linked, and pay for an officer's duties as an employee, aside; even then the part that is unreasonably high is not deductible, nor is any pay accounted for by concealing or disguising facts. Donations (寄附金) — gifts or free provision of money, assets or economic benefit, whatever they are called, including the gift element of a sale below value but not advertising, samples, entertainment or welfare costs — are deductible only up to a limit a Cabinet Order (政令) works out from capital and income. Donations to the national or a local government that give the donor no special benefit, and donations the Minister of Finance designates, are left out of that count, so they are deductible in full, while donations to another domestic corporation with which the donor has a relationship of full control by a corporation (完全支配関係) are not deductible, as far as they match the gift income the recipient leaves out of its own income.(Art. 2(1)(xv), Art. 34(1), Art. 34(1)(i), Art. 34(1)(ii), Art. 34(1)(iii), Art. 34(2), Art. 34(3), Art. 37(1), Art. 37(2), Art. 37(3), Art. 37(7), Art. 37(8)) (the provisions it rests on)
  • The corporation's own corporation tax and local corporation tax (地方法人税) (apart from a few items, such as interest tax on an extended return), its prefectural and municipal inhabitants' taxes, additional taxes and delinquency tax on national taxes and their local equivalents, fines and administrative fines (including foreign ones), surcharges under the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (私的独占の禁止及び公正取引の確保に関する法律) and the other Acts this Act lists, bribes, and the cost of concealing or disguising facts to cut its tax are not deductible. Under Article 61-4 of the Act on Special Measures Concerning Taxation (租税特別措置法), entertainment expenses (交際費等) — spending on entertaining, hospitality and gifts for customers, suppliers and others connected with the business, but not the usual cost of employee recreation or food and drink costs within a per-person amount a Cabinet Order (政令) sets — in business years beginning from 1 April 2014 to 31 March 2027 are not deductible either, except half of food and drink expenses (other than those solely for its own officers and employees, and recorded as a Ministry of Finance Order requires) for a corporation with capital of 10,000,000,000 yen or less. A corporation with capital of 100 million yen or less (not wholly owned by a large corporation, among other exclusions) may instead deduct up to 8,000,000 yen of them a year.(Art. 38(1), Art. 38(2), Art. 55(1), Art. 55(4), Art. 55(5), Art. 55(6), Act on Special Measures Concerning Taxation Art. 61-4(1), Act on Special Measures Concerning Taxation Art. 61-4(2), Act on Special Measures Concerning Taxation Art. 61-4(6), Act on Special Measures Concerning Taxation Art. 61-4(6)(i), Act on Special Measures Concerning Taxation Art. 61-4(6)(ii)) (the provisions it rests on)
  • A domestic corporation must file a final return (確定申告書) with the district director of the tax office (), based on its approved accounts and with its balance sheet and profit and loss statement, within two months after each business year ends, and pay the tax by then; the director may, on application, set a later deadline where a disaster or other unavoidable reason keeps the accounts from being settled (unless the deadline is extended under Article 11 of the Act on General Rules for National Taxes (国税通則法)), and one whose articles or special circumstances keep its general meeting from being held within two months may, on application, have a month more, or up to four months as the director sets where it has an accounting auditor and its articles put the meeting more than three months after the year's end — in either case with interest tax (利子税) that this Act sets at 7.3% a year, though Article 93 of the Act on Special Measures Concerning Taxation (租税特別措置法) replaces that rate with the special base rate for interest tax (利子税特例基準割合) in any year that rate is lower. An ordinary corporation whose business year is longer than six months — other than in its first business year after being set up, among a few other cases — must also file an interim return (中間申告書) and pay within two months after the first six months, of the previous year's tax scaled to six months — not needed when that is 100,000 yen or less — or, in most cases, of the tax on provisional accounts for those six months. A corporation with capital of more than 100 million yen, members of a group under group tax sharing, mutual insurance companies, investment corporations and special purpose companies must file these returns online through the National Tax Agency's system.(Art. 74(1), Art. 74(3), Art. 77(1), Art. 75(1), Art. 75(7), Art. 75-2(1), Art. 75-2(8), Act on Special Measures Concerning Taxation Art. 93(1)(ii), Art. 71(1), Art. 71(1)(i), Art. 72(1), Art. 76(1), Art. 75-4(1), Art. 75-4(2)) (the provisions it rests on)
Article 1 sets out what this Act covers (趣旨)
Who pays corporation taxWorking out taxable incomeTax ratesLoss carryforwardOfficers' payFinal returnBlue returnsForeign corporations' domestic source income

Contents

262 2248 1020 344 1209

Amendments

A Japanese law is changed by another law or order that rewrites it — an . This law has 6 amendments on the way — , but . Its amendment history is below. The amendments this site has read the changes of are on this law's amendments page, provision by provision, in Japanese and English.

1 January 2027

in 3 months

Act Partially Amending the Income Tax Act, etc.

所得税法等の一部を改正する法律

1 April 2027

in 6 months

Act Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act

金融商品取引法及び資金決済に関する法律の一部を改正する法律

1 April 2027

in 6 months

Act Partially Amending the Immigration Control and Refugee Recognition Act and the Act on Proper Technical Intern Training and Protection of Technical Intern Trainees

出入国管理及び難民認定法及び外国人の技能実習の適正な実施及び技能実習生の保護に関する法律の一部を改正する法律

By 16 April 2027

at the latest, in 6 months

Act Partially Amending the Act on the Activation of Science, Technology and Innovation Creation

科学技術・イノベーション創出の活性化に関する法律の一部を改正する法律

On a day set by , no later than 16 April 2027 — the amending law allows up to nine months from . The exact day is not fixed yet.

By 22 July 2027

at the latest, in 9 months

Act Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act

金融商品取引法及び資金決済に関する法律の一部を改正する法律

On a day set by , no later than 22 July 2027 — the amending law allows up to one year from . The exact day is not fixed yet.

By 19 June 2030

at the latest, in 4 years

Act Partially Amending the National Pension Act, etc., and Other Matters, to Strengthen the Functions of the Pension System in Light of Socioeconomic Changes

社会経済の変化を踏まえた年金制度の機能強化のための国民年金法等の一部を改正する等の法律

On a day set by , no later than 19 June 2030 — the amending law allows up to five years from . The exact day is not fixed yet.

63 amendments already in force
  • 1 October 2026

    The text on this site

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 October 2026

    Science Council of Japan Act

    日本学術会議法

  • 1 October 2026

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 12 August 2026

    Act Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act

    金融商品取引法及び資金決済に関する法律の一部を改正する法律

  • 23 July 2026

    Act Partially Amending the Financial Instruments and Exchange Act and the Payment Services Act

    金融商品取引法及び資金決済に関する法律の一部を改正する法律

  • 1 April 2026

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2026

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2026

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 January 2026

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 18 December 2025

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 20 June 2025

    Act Partially Amending the National Pension Act, etc., and Other Matters, to Strengthen the Functions of the Pension System in Light of Socioeconomic Changes

    社会経済の変化を踏まえた年金制度の機能強化のための国民年金法等の一部を改正する等の法律

  • 1 June 2025

    Act on the Arrangement of Related Acts upon the Enforcement of the Act Partially Amending the Penal Code, etc. (extract)

    刑法等の一部を改正する法律の施行に伴う関係法律の整理等に関する法律 抄

  • 1 April 2025

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2025

    Act Partially Amending the Basic Act on the Formation of a Digital Society, etc. to Improve Convenience for Persons Concerned in Administrative Procedures, etc. and to Simplify and Streamline Administrative Operations through the Use of Information and Communications Technology

    情報通信技術の活用による行政手続等に係る関係者の利便性の向上並びに行政運営の簡素化及び効率化を図るためのデジタル社会形成基本法等の一部を改正する法律

  • 1 April 2025

    Act on the Arrangement of Related Acts upon the Enforcement of the Act on Japan Institute for Health Security

    国立健康危機管理研究機構法の施行に伴う関係法律の整備に関する法律

  • 1 April 2025

    Act Partially Amending the Private Schools Act

    私立学校法の一部を改正する法律

  • 1 January 2025

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 October 2024

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2024

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2024

    Act Partially Amending the Financial Instruments and Exchange Act, etc.

    金融商品取引法等の一部を改正する法律

  • 1 April 2024

    Act Partially Amending the Electricity Business Act, etc. to Establish an Electricity Supply System for Realizing a Decarbonized Society

    脱炭素社会の実現に向けた電気供給体制の確立を図るための電気事業法等の一部を改正する法律

  • 1 April 2024

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 February 2024

    Act Partially Amending the Financial Instruments and Exchange Act, etc.

    金融商品取引法等の一部を改正する法律

  • 29 November 2023

    Act Partially Amending the Financial Instruments and Exchange Act, etc.

    金融商品取引法等の一部を改正する法律

  • 7 June 2023

    Act on the Arrangement of Related Acts upon the Enforcement of the Act on Japan Institute for Health Security

    国立健康危機管理研究機構法の施行に伴う関係法律の整備に関する法律

  • 7 June 2023

    Act Partially Amending the Electricity Business Act, etc. to Establish an Electricity Supply System for Realizing a Decarbonized Society

    脱炭素社会の実現に向けた電気供給体制の確立を図るための電気事業法等の一部を改正する法律

  • 1 June 2023

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2023

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 January 2023

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 31 December 2022

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 October 2022

    Act Partially Amending the Workers' Cooperatives Act, etc.

    労働者協同組合法等の一部を改正する法律

  • 1 October 2022

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 17 June 2022

    Act on the Arrangement of Related Acts upon the Enforcement of the Act Partially Amending the Penal Code, etc.

    刑法等の一部を改正する法律の施行に伴う関係法律の整理等に関する法律

  • 1 May 2022

    Act Partially Amending the National Pension Act, etc. to Strengthen the Functions of the Pension System

    年金制度の機能強化のための国民年金法等の一部を改正する法律

  • 1 April 2022

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2022

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2022

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 August 2021

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2021

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 March 2021

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 12 June 2020

    Act Partially Amending the Electricity Business Act, etc. to Establish a Resilient and Sustainable Electricity Supply System

    強靱かつ持続可能な電気供給体制の確立を図るための電気事業法等の一部を改正する法律

  • 5 June 2020

    Act Partially Amending the National Pension Act, etc. to Strengthen the Functions of the Pension System

    年金制度の機能強化のための国民年金法等の一部を改正する法律

  • 1 May 2020

    Act Partially Amending the Payment Services Act, etc. to Respond to the Diversification of Financial Transactions Accompanying Advances in Information and Communications Technology

    情報通信技術の進展に伴う金融取引の多様化に対応するための資金決済に関する法律等の一部を改正する法律

  • 1 April 2020

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2020

    Act Partially Amending the Act on Use of Information and Communications Technology in Administrative Procedures, etc., and Other Acts to Improve Convenience for Persons Concerned in Administrative Procedures, etc. and to Simplify and Streamline Administrative Operations through the Use of Information and Communications Technology

    情報通信技術の活用による行政手続等に係る関係者の利便性の向上並びに行政運営の簡素化及び効率化を図るための行政手続等における情報通信の技術の利用に関する法律等の一部を改正する法律

  • 1 April 2020

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 January 2020

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 October 2019

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 October 2019

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 7 June 2019

    Act Partially Amending the Payment Services Act, etc. to Respond to the Diversification of Financial Transactions Accompanying Advances in Information and Communications Technology

    情報通信技術の進展に伴う金融取引の多様化に対応するための資金決済に関する法律等の一部を改正する法律

  • 1 April 2019

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2019

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 January 2019

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 16 November 2018

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2018

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 April 2018

    Act Partially Amending the Agricultural Disaster Compensation Act

    農業災害補償法の一部を改正する法律

  • 1 April 2018

    Act Partially Amending the Income Tax Act, etc.

    所得税法等の一部を改正する法律

  • 1 January 2018

    Act Partially Amending the Income Tax Act, etc., and Other Matters

    所得税法等の一部を改正する等の法律

  • 1 November 2017

    Act on Proper Technical Intern Training and Protection of Technical Intern Trainees

    外国人の技能実習の適正な実施及び技能実習生の保護に関する法律

  • 1 October 2017

    Act Partially Amending the Income Tax Act, etc., and Other Matters

    所得税法等の一部を改正する等の法律

  • 1 April 2017

    Act Partially Amending the Income Tax Act, etc., and Other Matters

    所得税法等の一部を改正する等の法律

  • 1 April 2017

    Act Partially Amending the Act on Compensation of Damages Related to Fishing Vessels and the Act on Compensation of Fishery Disaster, and Other Matters, to Improve the Compensation Systems for Fishery Management

    漁業経営に関する補償制度の改善のための漁船損害等補償法及び漁業災害補償法の一部を改正する等の法律

  • 1 April 2017

    Act Partially Amending the Electricity Business Act, etc., and Other Matters

    電気事業法等の一部を改正する等の法律

Who it applies to

It applies to

  • Domestic corporations (内国法人) — corporations with their head or main office in Japan — on their income for each business year: ordinary corporations (普通法人) and the cooperatives (協同組合等) listed in Appended Table 3 are taxed on all of it, foreign-source income included, as the credit for foreign corporation tax paid on it up to a limit shows (Article 69), and income tax withheld from interest, dividends and the other payments listed in Article 174 of the Income Tax Act (所得税法) that they receive is deducted from their corporation tax for the year, as a Cabinet Order (政令) sets (Article 68). A newly established ordinary corporation or cooperative must notify the district director of the tax office of its place for tax payment, its purpose and the day it was set up within two months, with a copy of its articles.(Art. 2(1)(iii), Art. 2(1)(vii), Art. 2(1)(ix), Art. 4(1), Art. 5(1), Art. 69(1), Art. 148(1), Appended Table 3, Art. 68(1)) (the provisions it rests on)
  • Corporations in the public interest, etc. (公益法人等) listed in Appended Table 2 — among them public interest incorporated associations and foundations, school corporations, social welfare corporations, religious corporations and non-profit general incorporated associations and foundations — and associations or foundations without legal personality that have a named representative or manager (人格のない社団等), which the Act treats as corporations: they pay corporation tax only on income from a profit-making business (収益事業), a sales, manufacturing or other business a Cabinet Order (政令) names that is carried on continuously at a fixed place of business, and in the few other cases the Act lists, such as taking on a trust taxed as a corporation. One that starts a profit-making business must notify the district director of the tax office within two months.(Art. 2(1)(vi), Art. 2(1)(viii), Art. 2(1)(xiii), Art. 3(1), Art. 4(1), Art. 6(1), Art. 150(1), Appended Table 2) (the provisions it rests on)
3 more
  • Foreign corporations (外国法人) — any corporation other than a domestic one — pay the tax on each business year's income on their domestic source income (国内源泉所得) only: one with a permanent establishment (恒久的施設) in Japan — a branch, factory or other fixed place of business, a construction or installation site, or a person in Japan with authority to conclude contracts on its behalf, as a Cabinet Order (政令) sets — is taxed on the income attributable to it as if it were an independent business and on other domestic source income, and one without is taxed on that other income only. That other income is income from using or holding assets in Japan (apart from kinds listed in Article 161(1) of the Income Tax Act (所得税法)), from selling assets in Japan as a Cabinet Order sets, from a personal-services business carried on in Japan, from letting real estate in Japan or leasing ships or aircraft to residents or domestic corporations, and other income a Cabinet Order sets. The rate is 23.2%, with 19% on the first 8,000,000 yen a year for an ordinary corporation with capital of 100 million yen or less, or none (apart from those Article 143(5) names), and for associations without legal personality, and the lower rate noted above; each files a final return within two months after each business year ends, or earlier when it gives up its permanent establishment without notifying a tax agent (納税管理人) or ends its personal-services business in Japan, and a foreign ordinary corporation that comes to have a permanent establishment or taxable income in Japan must notify the tax office within two months, unless a treaty exempts all of that income.(Art. 2(1)(iv), Art. 2(1)(xii-19), Art. 2(1)(xii-19)(a), Art. 2(1)(xii-19)(b), Art. 2(1)(xii-19)(c), Art. 4(3), Art. 8(1), Art. 138(1), Art. 138(1)(i), Art. 138(1)(ii), Art. 138(1)(iii), Art. 138(1)(iv), Art. 138(1)(v), Art. 138(1)(vi), Art. 141(1), Art. 143(1), Art. 143(2), Art. 144-6(1), Art. 144-6(2), Art. 149(1), Act on Special Measures Concerning Taxation Art. 42-3-2(1), Art. 143(5)) (the provisions it rests on)
  • Members of a multinational group whose total revenue was 750 million euros or more in at least two of its four preceding fiscal years (特定多国籍企業グループ等): a member that is a domestic corporation, or a foreign corporation with a permanent establishment in Japan, pays corporation tax worked out on a share of the top-up left uncollected elsewhere (国際最低課税残余額) and on the top-up for the group's own entities in Japan (国内最低課税額), and a domestic corporation that is the group's parent or an intermediate parent also pays it on the top-up needed, after an allowance for payroll and tangible assets, to bring the tax of the group's entities abroad up to the 15% base rate in each country where their effective tax rate is lower (国際最低課税額). Each files a return for any such tax it owes — online where its capital exceeds 100 million yen or it is a mutual insurance company, investment corporation or special purpose company — and the group's information return online, within one year and three months after the end of the group's fiscal year, or one year and six months the first time. In a country where the group's average revenue is below 10 million euros and its average profit below 1 million euros, the top-up for the year can be treated as zero if the information return says so.(Art. 82(1)(iv), Art. 82(1)(xxxi), Art. 6-2(1), Art. 6-3(1), Art. 6-4(1), Art. 8-2(1), Art. 8-3(1), Art. 82-3(1), Art. 82-3(2), Art. 82-3(8), Art. 82-3(11), Art. 82-11(1), Art. 82-19(1), Art. 82-6(1), Art. 82-6(2), Art. 82-14(1), Art. 82-22(1), Art. 150-3(1), Art. 150-3(9), Art. 82-7(1), Art. 82-7(2), Art. 82-15(1), Art. 82-23(1)) (the provisions it rests on)
  • Trustees of trusts taxed as corporations (法人課税信託) — among them trusts that issue beneficiary certificates, trusts with no beneficiary, certain trusts a corporation makes of its business, and investment trusts other than collective investment trusts (集団投資信託) — including individual trustees: each such trust's assets, liabilities, revenue and expenses are treated as belonging to a separate person, which pays corporation tax as a domestic corporation if the trust's office is in Japan and as a foreign corporation if it is not.(Art. 2(1)(xxix-2), Art. 4(4), Art. 4-2(1), Art. 4-2(2), Art. 4-3(1)(i), Art. 4-3(1)(ii)) (the provisions it rests on)

It does not apply to

  • Public service corporations (公共法人) listed in Appended Table 1 — among them local governments, national university corporations, Japan Finance Corporation, Japan Pension Service and the Japan Broadcasting Corporation (日本放送協会) — have no duty to pay corporation tax.(Art. 4(2), Art. 2(1)(v), Appended Table 1) (the provisions it rests on)
Special rules and exceptions (6)
  • A family company more than half owned by one shareholder and those specially connected with it (被支配会社) — broadly, a specified family company (特定同族会社) — pays, on top of its usual tax, 10% of its retained income (留保金額) beyond a deduction up to 30,000,000 yen a year, 15% from there up to 100,000,000 yen and 20% above that — the deduction being the largest of 40% of its income as the Act adjusts it, 20,000,000 yen a year, and the amount by which its earned surplus falls short of a quarter of its capital. This does not apply to a company in liquidation, nor to one with capital of 100 million yen or less unless it is wholly owned by a large corporation or is another of the kinds Article 66(5)(ii) to (v) names (among them investment corporations and special purpose companies), or a group tax sharing member in a group where a member has capital of more than 100 million yen, among others.(Art. 67(1), Art. 67(1)(i), Art. 67(1)(ii), Art. 67(1)(iii), Art. 67(2), Art. 67(5)) (the provisions it rests on)
  • Small corporations (stated capital of 100 million yen or less, or none, and not wholly owned by a large corporation, among other exclusions), corporations in the public interest, cooperatives, associations without legal personality, banks, insurance companies and similar corporations a Cabinet Order (政令) adds, and corporations with financial claims a Cabinet Order sets may deduct sums they book as an expense in their accounts (損金経理) to a bad debt allowance (貸倒引当金) for expected losses on their receivables, up to limits a Cabinet Order sets, if their final return gives the details — though not in the year before a merger that is not qualified, or the year its residual assets are fixed in a liquidation; the sum is added back to income the next year.(Art. 52(1), Art. 52(1)(i), Art. 52(1)(ii), Art. 52(1)(iii), Art. 52(2), Art. 52(3), Art. 52(10)) (the provisions it rests on)
  • The 1% corporation tax this Act puts on the retirement pension reserves (退職年金等積立金) of trust banks, life insurers and others doing retirement pension business — managing corporate pension and similar assets for employers and workers — is not charged for business years beginning from 1 April 1999 to 31 March 2029, under Article 68-5 of the Act on Special Measures Concerning Taxation (租税特別措置法).(Art. 7(1), Art. 84(1), Art. 87(1), Act on Special Measures Concerning Taxation Art. 68-5(1)) (the provisions it rests on)
  • A domestic ordinary corporation or cooperative that is not itself wholly owned by another, and all its eligible wholly owned domestic subsidiaries (corporations in liquidation, investment corporations, special purpose companies and others the Act lists left out), may, with the approval of the Commissioner of the National Tax Agency () applied for jointly at least three months before the first business year concerned, use group tax sharing (通算制度): a loss of one member is set against the income of the others in proportion to their income, and each is jointly liable for the others' corporation tax for that period. A member loses its losses from business years that began before its approval took effect, unless it is among those the Act spares from valuing their assets at market value on starting or joining — and even then it loses some of them if it has not been under the group's control for five years and starts a new business, unless the group carries on a joint business.(Art. 64-9(1), Art. 64-9(2), Art. 64-5(1), Art. 64-5(2), Art. 64-5(3), Art. 152(1), Art. 57(6), Art. 57(8), Art. 64-11(1), Art. 64-12(1)) (the provisions it rests on)
  • In a qualified merger (適格合併), qualified company split (適格分割) or qualified contribution in kind (適格現物出資) — broadly, one paid only in shares of the acquiring company or its full parent, between companies of a group under full control, or of a group with more than 50% control where about 80% of the staff and the main business carry on, or for a joint business meeting conditions a Cabinet Order (政令) sets — the assets and liabilities pass at book value, so no gain or loss is taxed then; in any other merger or split they are treated as sold at their value at that time. On a qualified merger the merged company's unused losses pass to the acquirer, with limits where their control relationship began less than five years before and the merger is not one for a joint business.(Art. 2(1)(xii-8), Art. 2(1)(xii-11), Art. 2(1)(xii-14), Art. 62(1), Art. 62(2), Art. 62-2(1), Art. 62-2(2), Art. 62-3(1), Art. 62-4(1), Art. 57(2), Art. 57(3)) (the provisions it rests on)
  • Where a tax treaty Japan has concluded — which is outside this collection — defines a permanent establishment (恒久的施設) or domestic source income differently from this Act, the treaty's definition applies to the foreign corporations it covers, and a foreign corporation whose taxable income here is all exempted by a treaty or by other provisions a Cabinet Order (政令) sets need not file a final return.(Art. 2(1)(xii-19), Art. 139(1), Art. 144-6(1), Art. 144-6(2)) (the provisions it rests on)
How it is enforced (6)
  • A representative, agent, employee or other worker of a corporation who, by deception or other wrongful acts, escapes corporation tax or obtains a refund by carrying back a loss is punishable by imprisonment () of up to ten years or a fine of up to 10,000,000 yen, or both, and the fine can be raised to the amount of tax escaped or refunded where that is higher. Escaping tax by not filing a required return by its deadline is punishable by up to five years or a fine of up to 5,000,000 yen (or up to the tax escaped, if more), or both. Where the offence is committed in the course of the corporation's business, the corporation is fined the same as well (Article 163).(Art. 159(1), Art. 159(2), Art. 159(3), Art. 159(4), Art. 163(1)) (the provisions it rests on)
  • Failing without good reason to file a final return by its deadline, or to provide by its deadline the information return on the global minimum tax that a large multinational group must give, is punishable by imprisonment of up to one year or a fine of up to 500,000 yen, though the penalty may be waived in light of the circumstances; filing an interim return on provisional accounts, among others, with false entries, or giving false information in that information return, carries the same penalties. Where a representative, agent or employee commits any of these offences, or the tax evasion of Article 159, in the course of the business, the corporation or employer is fined under the same article as well as the person who acted.(Art. 160(1), Art. 162(1), Art. 163(1), Art. 150-3(1), Art. 150-3(4), Art. 159(1), Art. 159(3)) (the provisions it rests on)
  • The district director of the tax office reassesses (更正) a return whose figures are wrong, and determines (決定) the tax of a corporation that should have filed and did not, under Articles 24 and 25 of the Act on General Rules for National Taxes (国税通則法), and may estimate a corporation's income from its assets and debts, income and spending, or the scale of its business — but not the income on a blue return (青色申告書). A blue return can be reassessed only after the director has examined the corporation's books and found an error, unless the error shows on the face of the return and its attachments, and the notice of reassessment must give the reasons; these rules apply to foreign corporations' tax as well. Where the acts or accounts of a family company (同族会社) or certain similar corporations, of the parties to a reorganization, or of a member of a group under group tax sharing would unjustly reduce corporation tax if accepted, the director may work out the tax as the director sees fit, disregarding them.(Act on General Rules for National Taxes Art. 24(1), Act on General Rules for National Taxes Art. 25(1), Art. 131(1), Art. 130(1), Art. 130(2), Art. 132(1), Art. 132-2(1), Art. 132-3(1), Art. 147(1)) (the provisions it rests on)
  • A corporation, domestic or foreign, may file blue returns (青色申告書) with the approval of the district director of the tax office, applied for before the business year begins (a new corporation, within three months of being set up or by the end of its first business year if that comes sooner; a corporation in the public interest or association without legal personality, likewise from starting a profit-making business), and an application not decided by the year's end (or by the six-month mark, for one that files an interim return) is deemed approved; once approved, it must keep books and record its transactions as a Ministry of Finance Order requires, and the director may give it instructions on those books. The director may withdraw the approval, back to the year concerned, where the books are not kept as required, the director's instructions are not followed, transactions are hidden or disguised in the books or there is other good reason to doubt their truth as a whole, or the final return was not filed by its deadline. Ordinary corporations, cooperatives, and corporations in the public interest and associations without legal personality carrying on a profit-making business, if they have no approval, must still keep books recording their transactions by a simple method a Ministry of Finance Order sets, and officials examine those books in an investigation unless something makes that difficult.(Art. 121(1), Art. 122(1), Art. 122(2), Art. 122(2)(i), Art. 122(2)(ii), Art. 125(1), Art. 126(1), Art. 126(2), Art. 127(1), Art. 146(1), Art. 150-2(1), Art. 150-2(2)) (the provisions it rests on)
  • When investigating corporation tax, officials of the National Tax Agency, the regional taxation bureaus and tax offices may, where necessary, question the corporation and those who owe it payments or goods or are owed them by it, inspect their business books and other records, and require them to be shown or handed over, under Article 74-2 of the Act on General Rules for National Taxes (国税通則法).(Act on General Rules for National Taxes Art. 74-2(1), Act on General Rules for National Taxes Art. 74-2(1)(ii)) (the provisions it rests on)
  • Filing late, under-declaring or not filing brings the additional taxes (加算税) of the Act on General Rules for National Taxes (国税通則法): an under-reporting penalty of 10% of the extra tax plus 5% on the part above the larger of the tax first declared and 500,000 yen — 5% in all if the corporation corrects its return before the investigation signals a reassessment, and none if it does so before being notified of an investigation — and a no-return penalty of 15% of the tax up to 500,000 yen, 20% from there to 3,000,000 yen and 30% above that, each 5% less for a late return filed before a determination is signalled and 5% in all for one filed before notice of an investigation, not charged where there was good reason for not filing or for a return filed within a month of the deadline by a corporation that meant to file on time, as a Cabinet Order (政令) sets. Where facts were hidden or disguised, a heavy additional tax of 35% or 40% is charged instead, 10% more where a no-return penalty or heavy additional tax was charged on the same kind of tax in the previous five years, among other cases; and tax paid late bears delinquency tax (延滞税) of 7.3% a year until two months after the due date and 14.6% after that. Article 94 of the Act on Special Measures Concerning Taxation (租税特別措置法) replaces those delinquency tax rates in any year its special base rate for delinquency tax (延滞税特例基準割合) is below 7.3%: 14.6% becomes that rate plus 7.3%, and 7.3% becomes that rate plus 1%, at most 7.3%.(Act on General Rules for National Taxes Art. 65(1), Act on General Rules for National Taxes Art. 65(2), Act on General Rules for National Taxes Art. 65(6), Act on General Rules for National Taxes Art. 66(1), Act on General Rules for National Taxes Art. 66(2), Act on General Rules for National Taxes Art. 66(3), Act on General Rules for National Taxes Art. 66(8), Act on General Rules for National Taxes Art. 66(9), Act on General Rules for National Taxes Art. 68(1), Act on General Rules for National Taxes Art. 68(2), Act on General Rules for National Taxes Art. 68(4), Act on General Rules for National Taxes Art. 60(1), Act on General Rules for National Taxes Art. 60(2), Act on Special Measures Concerning Taxation Art. 94(1)) (the provisions it rests on)

How it connects to other laws

Where the translation comes from

  • 475
  • 4,493

The Ministry of Justice translated only part of this law: the limited to the provisions related to foreign corporations, as the law stood after Act No. 23 of 2008 amended it. The rest of the law has no Ministry translation.

The Ministry of Justice's translation is shown only where the Japanese it translates matches the law in force today. Everywhere else the English is a machine translation, marked on the paragraph itself.

Only the Japanese is the law, and no lawyer has reviewed the machine translation.

Sources

Everything this page rests on

  • e-Gov (Digital Agency)法人税法 — the text in force from 2026-10-01Original
  • e-Gov (Digital Agency)法人税法 — revision historyOriginal
  • Japanese Law Translation, Ministry of JusticeCorporation Tax Act — Ministry of Justice translationOriginal
  • Machine translation, not official
  • Written for this site with AIEnglish titles of amending laws, written for this site
  • Written for this site with AIDescriptions of each law, written for this site
  • Written for this site with AISlips in the Ministry of Justice's English of the Corporation Tax Act, corrected
  • Worked out by this site from e-Gov's text