Key implementation point
April fiscal year start means Japan's first IIR period was April 2024, not January 2024. UTPR deferred a full year beyond IIR.
Implementation detail
- 01 Japan's fiscal year typically starts 1 April — IIR effective for years beginning on or after 1 April 2024.
- 02 UTPR deferred to years beginning on or after 1 April 2025.
- 03 JQDMTT (Japanese QDMTT) effective from 1 April 2024.
- 04 Japan's existing high effective CT rate (~31%) means most Japanese domestic entities will not trigger top-up.
- 05 Japanese R&D tax credits and incentive schemes: credits are non-refundable and reduce covered taxes.
- 06 NTA (National Tax Agency) issued detailed administrative guidance.
- 07 Japan is a major UPE jurisdiction for global MNEs — IIR is therefore particularly significant for Japan-parented groups.
Enacted legislation
Tokutei Taishokoku Shōhi Zei (Special Taxpayer Income Minimum Tax)
Official sources & further reading
Track Japan rules against your live MNE
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