Article 150-3Provision of Report Items, etc. Pertaining to Specified Multinational Enterprise Groups, etc.

①A domestic corporation that is a constituent entity (meaning a constituent entity prescribed in Article 82, item (xiii) (hereinafter referred to as a "constituent entity" in this Article), limited to one whose country of location (meaning the country of location prescribed in Article 82, item (vii); hereinafter the same applies in this Article) is Japan) belonging to a specified multinational enterprise group, etc. (meaning a specified multinational enterprise group, etc. prescribed in Article 82, item (iv) (Definitions); hereinafter the same applies in this Article), or a foreign corporation that is a constituent entity having a permanent establishment, etc. (meaning a permanent establishment, etc. prescribed in Article 82, item (vi), limited to one whose country of location is Japan; the same applies in paragraph (4)) belonging to that specified multinational enterprise group, etc. (hereinafter referred to as a "group international minimum tax reporting corporation" in this Article) must provide the following matters pertaining to each covered fiscal year of that specified multinational enterprise group, etc. (referred to as "group international minimum tax report items, etc." in the following paragraph, paragraphs (3) and (9), and Article 160 (Penal Provisions)) to the competent district director with jurisdiction over the place for tax payment of that group international minimum tax reporting corporation, within one year and three months from the day following the last day of that covered fiscal year, as specified by Ministry of Finance Order, by a method using an electronic data processing system (meaning the method specified by Ministry of Finance Order as a method using an electronic data processing system that connects, via a telecommunications line, a computer (including an input-output device; hereinafter the same applies in this paragraph) used by the National Tax Agency, the use of which is notified to the district director in advance as specified by Ministry of Finance Order, with a computer used by the corporation making the provision; hereinafter the same applies in this Article and Article 162 (Penal Provisions)).

②If there are two or more corporations that are required under the provisions of the preceding paragraph to provide the group international minimum tax report items, etc. pertaining to the specified multinational enterprise group, etc. referred to in that paragraph, and any one of those corporations, on behalf of those corporations, has provided the name of the corporation that is to provide the group international minimum tax report items, etc. under the provisions of that paragraph and other matters specified by Ministry of Finance Order to the competent district director with jurisdiction over the place for tax payment of that one corporation, within one year and three months from the day following the last day of each covered fiscal year referred to in that paragraph, by a method using an electronic data processing system, the corporations other than the corporation designated to provide the group international minimum tax report items, etc. under the provisions of that paragraph on their behalf are not required to provide the group international minimum tax report items, etc. under the provisions of that paragraph, notwithstanding the provisions of that paragraph. In this case, with regard to the application of the provisions of that paragraph to the corporation designated to provide them on behalf of the others, the phrase "(referred to as 'group international minimum tax report items, etc.' in the following paragraph" in that paragraph is deemed to be replaced with "(including those matters pertaining to the corporations that are not required to provide those matters pursuant to the provisions of the first sentence of the following paragraph; referred to as 'group international minimum tax report items, etc.' in that paragraph".

④A group domestic minimum tax reporting corporation (meaning a domestic corporation that is a constituent entity (limited to one whose country of location is Japan) belonging to a specified multinational enterprise group, etc.; a domestic corporation that was a constituent entity (limited to one whose country of location is Japan) belonging to that specified multinational enterprise group, etc. in a past covered fiscal year (meaning a past covered fiscal year prescribed in Article 82, item (xxxii); hereinafter the same applies in this paragraph) and that is not such a constituent entity in the reporting fiscal year (meaning the covered fiscal year to which the provisions of this paragraph, paragraph (7) or paragraph (9) are applied; hereinafter the same applies in this paragraph) (limited to one that has a domestic minimum tax amount prescribed in Article 82-19, paragraph (1) (Domestic Minimum Tax Amount) for that reporting fiscal year); a domestic corporation that is a jointly controlled entity, etc. prescribed in Article 82, item (xv) (limited to one whose country of location is Japan) pertaining to that specified multinational enterprise group, etc.; a domestic corporation that was a jointly controlled entity, etc. prescribed in that item (limited to one whose country of location is Japan) pertaining to that specified multinational enterprise group, etc. in a past covered fiscal year and that is not such a jointly controlled entity, etc. in that reporting fiscal year (limited to one that has a domestic minimum tax amount prescribed in that paragraph for that reporting fiscal year); a foreign corporation that is a constituent entity having a permanent establishment, etc. belonging to that specified multinational enterprise group, etc.; a foreign corporation that was a constituent entity having a permanent establishment, etc. belonging to that specified multinational enterprise group, etc. in a past covered fiscal year and that is not such a constituent entity in that reporting fiscal year (limited to one that has a domestic minimum tax amount prescribed in Article 145-6, paragraph (1) (Domestic Minimum Tax Amount) for that reporting fiscal year); a foreign corporation that is a jointly controlled entity, etc. prescribed in that item having a permanent establishment, etc. pertaining to that specified multinational enterprise group, etc.; or a foreign corporation that was a jointly controlled entity, etc. prescribed in that item having a permanent establishment, etc. pertaining to that specified multinational enterprise group, etc. in a past covered fiscal year and that is not such a jointly controlled entity, etc. in that reporting fiscal year (limited to one that has a domestic minimum tax amount prescribed in that paragraph for that reporting fiscal year); hereinafter the same applies in this paragraph, paragraph (7) and paragraph (9)) must provide the following matters pertaining to each covered fiscal year of that specified multinational enterprise group, etc. (referred to as "group domestic minimum tax report items, etc." in the following paragraph, paragraphs (6) and (9), and Article 160) to the competent district director with jurisdiction over the place for tax payment of that group domestic minimum tax reporting corporation, within one year and three months from the day following the last day of that covered fiscal year, as specified by Ministry of Finance Order, by a method using an electronic data processing system.

⑤If there are two or more corporations that are required under the provisions of the preceding paragraph to provide the group domestic minimum tax report items, etc. pertaining to the specified multinational enterprise group, etc. referred to in that paragraph, and any one of those corporations, on behalf of those corporations, has provided the name of the corporation that is to provide the group domestic minimum tax report items, etc. under the provisions of that paragraph and other matters specified by Ministry of Finance Order to the competent district director with jurisdiction over the place for tax payment of that one corporation, within one year and three months from the day following the last day of each covered fiscal year referred to in that paragraph, by a method using an electronic data processing system, the corporations other than the corporation designated to provide the group domestic minimum tax report items, etc. under the provisions of that paragraph on their behalf are not required to provide the group domestic minimum tax report items, etc. under the provisions of that paragraph, notwithstanding the provisions of that paragraph.

⑥The provisions of the preceding two paragraphs do not apply if the case falls under the case specified by Cabinet Order as a case in which the authority enforcing the laws and regulations on taxation of the country of location of the ultimate parent company, etc. of a specified multinational enterprise group, etc. is found to be able to provide Japan with information equivalent to the group domestic minimum tax report items, etc. pertaining to each covered fiscal year of the specified multinational enterprise group, etc.

⑦A group international minimum tax reporting corporation to which the provisions of paragraph (3) apply or a group domestic minimum tax reporting corporation to which the provisions of the preceding paragraph apply must provide the notification items on the ultimate parent company, etc. (meaning the matters specified by Ministry of Finance Order as information on the ultimate parent company, etc. of a specified multinational enterprise group, etc.; the same applies in the following paragraph and paragraph (9)) pertaining to each covered fiscal year of the specified multinational enterprise group, etc. referred to in paragraph (3) or the preceding paragraph to the competent district director with jurisdiction over the place for tax payment of that group international minimum tax reporting corporation or that group domestic minimum tax reporting corporation, within one year and three months from the day following the last day of that covered fiscal year, by a method using an electronic data processing system.

⑧If there are two or more corporations that are required under the provisions of the preceding paragraph to provide the notification items on the ultimate parent company, etc. pertaining to the specified multinational enterprise group, etc. referred to in that paragraph, and any one of those corporations, on behalf of those corporations, has provided the name of the corporation that is to provide the notification items on the ultimate parent company, etc. under the provisions of that paragraph and other matters specified by Ministry of Finance Order to the competent district director with jurisdiction over the place for tax payment of that one corporation, within one year and three months from the day following the last day of each covered fiscal year referred to in that paragraph, by a method using an electronic data processing system, the corporations other than the corporation designated to provide the notification items on the ultimate parent company, etc. under the provisions of that paragraph on their behalf are not required to provide the notification items on the ultimate parent company, etc. under the provisions of that paragraph, notwithstanding the provisions of that paragraph.

⑨With regard to the application of the provisions of paragraphs (1), (2), (4) and (5) and the preceding two paragraphs in the case where a group international minimum tax reporting corporation or a group domestic minimum tax reporting corporation is, for the first time, required under the provisions of paragraph (1), (4) or (7) to provide the group international minimum tax report items, etc., the group domestic minimum tax report items, etc. or the notification items on the ultimate parent company, etc. pertaining to a covered fiscal year of a specified multinational enterprise group, etc. (excluding the case where, for any covered fiscal year before that covered fiscal year, another corporation that was a constituent entity belonging to that specified multinational enterprise group, etc. or another corporation that was a jointly controlled entity, etc. prescribed in Article 82, item (xv) pertaining to that specified multinational enterprise group, etc. was required under those provisions to provide the group international minimum tax report items, etc., the group domestic minimum tax report items, etc. or the notification items on the ultimate parent company, etc. pertaining to that specified multinational enterprise group, etc.), the phrase "one year and three months" in those provisions is deemed to be replaced with "one year and six months".

⑩Necessary matters concerning the application of the provisions of the preceding paragraphs are specified by Cabinet Order.