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      By virtue of the 2023 tax reform, the exemption threshold of effective tax rate for full-inclusion rules applied to the Specified CFC under the Controlled Foreign Company regime will be reduced to 27 percent from 30 percent.

      In this newsletter, we will provide an outline of the amendment and explain the possible impact from the amendment on deferred tax accounting for the fiscal year ending on or after 31 March 2023.
       

      Contents

      1. Amendment to Exemption Threshold of Effective Tax Rate for Full-inclusion Rules Applied to Specified CFC
      2. Impact on Deferred Tax Accounting

       

      Japanese Text

      2023年度税制改正 - 特定外国関係会社の会社単位の合算課税に係る閾値の見直し

       2023 Tax Reform - Amendment to CFC Regime - KPMG Japan Tax Newsletter

      2023 Tax Reform - Amendment to CFC Regime

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