CbCR Notification in Japan

Japanese corporations or foreign corporations with PE that is a Constituent entity of a Specified MNE Group must submit a Notification for Ultimate Parent Entity, which includes information on the Ultimate Parent Entity and Surrogate Parent Entity, to the competent District Director via e-Tax by the day when the fiscal year covered by the Notification ends (Article 66.4.4 Paragraph 5 of the Act on Special Measures Concerning Taxation (hereinafter referred to as the “Act”)).

In principle, if there are several Japanese corporations and foreign corporations with PE that must submit a Notification for Ultimate Parent Entity, all of them have the duty to do so. But as an exception, if one of the corporations submits information (Note) on those which it represents when it submits a Notification for Ultimate Parent Entity to the competent District Director via e-Tax by the day when the fiscal year covered by the Notification ends, the other corporations do not need to submit a Notification for Ultimate Parent Entity (Article 66.4.4 Paragraph 6 of the Act).

(Note)
The major content of the information to be submitted is as follows (Article 22.10.4 Paragraph 10 of the Ordinance for Enforcement of the Act on Special Measures Concerning Taxation (hereinafter referred to as the “Ordinance”)):

• Name of the corporation that submits a Notification for Ultimate Parent Entity on behalf of others, the location of its head and other offices, its corporate number, the name of its representative, etc.
• Names of corporations other than the one that submits a Notification for Ultimate Parent Entity on behalf of others, the location of their head and other offices, their corporate numbers, the names of their representative, etc.