Article 143Tax Rate for a Foreign Corporation's Corporation Tax on Income for Each Business Year
第百四十三条(外国法人に係る各事業年度の所得に対する法人税の税率)
The amount of corporation tax imposed on a foreign corporation for income for each business year is to be the amount calculated by multiplying the amount of income categorized as domestic source income by a tax rate of 23.2 percent, for each category of the following domestic source income:
domestic source income listed in Article 141, item (i), (a) (Tax Base);
domestic source income listed in Article 141, item (i), (b); and
domestic source income specified in Article 141, item (ii).
In the case referred to in the preceding paragraph, with regard to the part of the amount that is eight million yen per annum or less out of the amount of income categorized as domestic source income of an ordinary corporation whose amount of stated capital or amount of capital contributions is 100 million yen or less at the end of each business year or which has no capital or investment at the end of each business year, or of an association or foundation without juridical personality, for each category of domestic source income listed in the items of that paragraph, the applicable tax rate is 19 percent, notwithstanding the provisions of the paragraph.
With regard to the application of the preceding paragraph to a foreign corporation whose business year is less than one year, the phrase "amount that is eight million yen per annum" in the paragraph is deemed to be replaced with "amount that is calculated by dividing eight million yen by 12 and then multiplying the result by the number of months of the relevant business year."
The number of months set forth in the preceding paragraph is calculated according to the calendar; a division of less than one month is counted as one month.
前項の月数は、暦に従つて計算し、一月に満たない端数を生じたときは、これを一月とする。
The provisions of paragraph (2) do not apply to an ordinary corporation which is a foreign corporation and which falls under any of the following corporations as of the end of each business year:
a corporation specified by Cabinet Order as being equivalent to a mutual company prescribed in the Insurance Business Act;
保険業法に規定する相互会社に準ずるものとして政令で定めるもの
a foreign corporation between which and a large corporation (meaning any of the following corporations; hereinafter the same applies in this item and the following item) there is a full controlling interest held by the large corporation:
A corporation whose amount of stated capital or amount of capital contributions is 500 million yen or more;
資本金の額又は出資金の額が五億円以上である法人
A mutual company prescribed in the Insurance Business Act (including a corporation listed in the preceding item);
保険業法に規定する相互会社(前号に掲げる法人を含む。)
A trust corporation as prescribed in Article 4-3 (Application of This Act to Trust Corporations) (referred to as a "trust corporation" in item (iv)).
an ordinary corporation (excluding a corporation listed in the preceding item) in the case where, if all of the shares and capital contributions held by all of the large corporations that have a full controlling interest with the ordinary corporation are deemed to be held by any one of those large corporations, there would be a full controlling interest held by that one corporation between that one corporation and the ordinary corporation; and