If a domestic company do international trade through foreign affiliates located in a low tax country or jurisdiction (tax haven), that company can avoid undue tax burden by going through this foreign affiliates, or even escape taxation in Japan as a result.
Controlled Foreign Companies (CFC) tax is a system to deal with those possible tax avoidance acts, by attributing a proportion of the income sheltered in tax haven to that of the domestic company and it imposes tax to the sum of those.
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