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We approach each audit with sharp thought, straight talk and common sense. In addition to verifying that financial results are fairly presented and meet...

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As a member firm of Grant Thornton International (GTIL), we provide international-standard audit & assurance services. We perform audit services effectively and efficiently by utilising our global audit methodologyo deliver consistent audit services globally and the integrated audit tool (Leap) to maintain audit quality and improve audit efficiency. Also our audit services are regularly reviewed by GTIL review team, thereby allowing us to further improve our audit quality.
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As your business grows, our advisory services are designed to help you achieve your goals. Successful growth often means navigating a complex array of...

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With expertise in visa, payroll, human capital and income tax, we adopt a multi-disciplinary and global approach to provide comprehensive solutions to businesses' most valuable asset-people.
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JAPAN TAX BULLETIN

Succeeding tax losses of a merged company in a statutory merger

2023/04/242 min read

Contents

A blue tax return status corporate taxpayer1 is allowed to carry forward tax losses to the following 10 business years and carry back to the previous one business year, to offset against the following business years’ income or claim a refund of the previous year’s tax. When a company carrying forward tax losses (a “tax loss holding company”) is merged into another company, the question is whether or not the tax losses of the merged company can survive in the merging company. Prior to the 2001 Tax Reform, the succession of tax losses of a merged company to a merging company was not allowed. In the 2001 Tax Reform, tax rules on corporate reorganizations were introduced into the Corporation Tax Law and the succession of tax losses of a merged company to a merging company in a qualified merger2 became possible. As a merger involving a tax loss holding company may be used for tax avoidance, special anti-avoidance rules were implemented in the Corporation Tax Law.

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