"Controlling relationship" and "fully controlling relationship," and "consolidated fully controlling relationship" are defined in Article 2, paragraphs 12-7-5, 12-7-6, and 12-7-7 of Corporate Tax Law of Japan ("CTL") as follows. For more about Japanese tax and accounting, click HERE:
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1. Controlling relationship is defined as follows in CTL Article 2, paragraph 12-7-5
- The relationship between a party* and a company where the party directly or indirectly owns at least 50% of the outstanding shares or contributed capital of the company
- The relationship between companies where at least 50% of the outstanding shares or contributed capital of each of these companies are directly or indirectly owned by a party*
2. Fully controlling relationship is defined as follows in CTL Article 2, paragraph 12-7-6
- The relationship between a party* and a company where the party directly or indirectly owns all the outstanding shares or contributed capital of the company
- The relationship between companies where all the outstanding shares or contributed capital of each of these companies are directly or indirectly owned by a party*
* For the purposes of the above definitions, a "party" where the party is an individual means that the party and individuals related to that individual.
3. Consolidated fully controlling relationship is defined as follows in CTL Article 2, paragraph 12-7-7
- The fully controlling relationship between a consolidated parent company and a consolidated subsidiary
- The relationship between consolidated subsidiaries where both subsidiaries have fully controlling relationship with the consolidated parent company
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