AKIA TAX CONSULTANTS K.K
Address：2F Shouei-Kannai Bldg.,2-22, Sumiyoshi-cho,Naka-ward, Yokohama City,
Kanagawa Prefecture,231-0013 Japan
Phone：＋81-45-308-6561
Fax：＋81-45-308-6562
Country-by- Country Report (CbCR)
Outline
・Reporting entity to submit it：
（Direct Filing）Japanese corporations that are a Constituent Entity of a Specified MNE Group
(limited to Ultimate or Surrogate Parent Entities)
(Local Filing*）Japanese corporations or foreign
corporations with PE that are a Constituent Entity of a Specified MNE Group (excluding Ultimate or Surrogate Parent Entities)
（Direct Filing）Japanese corporations that are a Constituent Entity of a Specified MNE Group
(limited to Ultimate or Surrogate Parent Entities)
(Local Filing*）Japanese corporations or foreign
corporations with PE that are a Constituent Entity of a Specified MNE Group (excluding Ultimate or Surrogate Parent Entities)
Items to be reported：On a tax jurisdiction-by-tax jurisdiction basis where the Constituent Entities of a Specified MNE Group conduct business,
1.Amounts of revenue, profit (loss) before income tax, income tax paid, income tax accrued, stated
capital, accumulated earnings, and tangible assets other than cash and cash equivalents, as well as
the number of employees
2.Names, Tax jurisdiction of organization or incorporation if different from tax jurisdiction of
residence, and major business activity(ies) of the Constituent Entities
3.Items that are deemed as useful for those listed above
1.Amounts of revenue, profit (loss) before income tax, income tax paid, income tax accrued, stated
capital, accumulated earnings, and tangible assets other than cash and cash equivalents, as well as
the number of employees
2.Names, Tax jurisdiction of organization or incorporation if different from tax jurisdiction of
residence, and major business activity(ies) of the Constituent Entities
3.Items that are deemed as useful for those listed above
・Start of application：Ultimate Parent Entity's fiscal year that begins on April 1, 2016 or thereafter
・Deadline for submission：Within one year of the day following the one when the Ultimate Parent
Entity's fiscal year ends
*Local Filing is only required if one of the followings applies
- The country in which the Ultimate Parent Entity has not taken necessary measures to require the
Entity to submit items equivalent to the CbCR
- There is no Qualifying Competent Authority Agreement between the Japanese Minister of Finance
and the competent authorities in the country in which the Ultimate Parent Entity resides
- The country in which the Ultimate Parent Entity resides is considered as unable to provide Japan
with information equivalent to the CbCR required in Japan on the day when the Ultimate Parent
Entity's fiscal year ends
Please contact us individually as Local Filing is a special case.
・Deadline for submission：Within one year of the day following the one when the Ultimate Parent
Entity's fiscal year ends
*Local Filing is only required if one of the followings applies
- The country in which the Ultimate Parent Entity has not taken necessary measures to require the
Entity to submit items equivalent to the CbCR
- There is no Qualifying Competent Authority Agreement between the Japanese Minister of Finance
and the competent authorities in the country in which the Ultimate Parent Entity resides
- The country in which the Ultimate Parent Entity resides is considered as unable to provide Japan
with information equivalent to the CbCR required in Japan on the day when the Ultimate Parent
Entity's fiscal year ends
Please contact us individually as Local Filing is a special case.