内国法人と外国法人からの受取配当金の取り扱いについて英語でまとめました(国税庁サイト)。
The tables below provides an overview of the treatment of dividends from Japanese/foreign corporations for Japanese corporate tax purposes. (Source: National Tax Agency)
Ownership |
Excludible
amount |
100% (e.g., shares in
wholly-owned subsidiary) |
100 % of dividends |
More than 1/3 (e.g.,
shares in related company) |
100% of dividends minus
related interest |
More than 5% and 1/3 or
less (e.g., other shares) |
50% of dividends |
5% or less (shares for
non-controlling purposes) |
20% of dividends |
Securities |
0% (fully non-excludable) |
Ownership |
Excludible
amount |
25% or more (i.e., foreign
subsidiary) subject to the following conditions: 1. The
Japanese parent company owns at least 25% of the outstanding shares in the
subsidiary. 2. The
Japanese parent company has owned such shares for at least 6 months immediately
before the date on which the dividend payment is determined. 3. No
amount of the dividend has been allowed as a deduction in the country where
the head office of the foreign subsidiary is located. |
95 % of dividends A foreign withholding tax is not creditable against corporate income tax or deductible from taxable income if the dividend is excluded from taxable income under this regime. |
Other foreign corporations |
0% (fully non-excludable)
|
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