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💴 | Impact on cash flow.What happens to the company's financial situation if there is a lot of inventory at the time of settlement?


The impact on cash flow.What happens to the company's financial situation if there is a lot of inventory at the time of settlement?

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Corporate tax

Corporate tax(Corporate tax,British: Corporate tax) IsCorporationIncome amount etc.Taxation standardIs imposed astax.National taxでDirect tax, In a broad senseincome taxA kind of. June 2021G7At the Treasury Ministers' Meeting, they agreed to set the international minimum tax rate at 15% or higher.[1][2].

Corporate tax base

Regarding the tax base of corporate tax, there is a theory that the tax should be borne according to the ability to bear the tax, and a theory that the tax should be borne according to the benefits given by the state. Underlying the idea of[3].. More practically, asking a corporation to bear the tax also means that a large tax revenue can be achieved with a small execution cost.[3].. Another reason is that if the profits accumulated as a result of corporate activities are not taxed, individual taxpayers will feel unfair.[3].

Jurist(English edition)Argues that the corporate tax system should be evaluated in terms of its impact on the tax system, taking into account tax burden allocation, growth, savings, investment and other financial and social perspectives.[4].

Character of corporate tax

Corporate tax is a tax in which the corporate entity of a corporate organization is the taxpayer and the income is the taxable property, and is a type of income tax in a broad sense.[5].. Corporate tax is classified as direct tax because the taxpayer and the taxpayer are the same.[5].. However, since the income earned at the corporate stage ultimately belongs to its members through dividends, etc., there are conflicting views on the nature of corporate tax.[6].. As will be described later, regarding the tax-bearing power of a corporation, there is a corporate fictitious theory that the tax-bearing power cannot be found in the corporation itself and a corporate reality theory that the tax-bearing power can be found in the corporation itself.[7].

Corporate tax-bearing power

Corporate pseudonym and corporate reality theory

The tax-bearing capacity of corporations can be divided into the following two ways of thinking.

  1. Corporate fiction theory-A corporation is simply a legal person, whose income belongs to shareholders and investors, and corporate tax is a prelude to income tax on these persons. Therefore, corporate tax is the personal income tax.Tax withholdingCan be equated with, economicalDouble taxationSince it is sufficient for individuals to eliminate the tax rate, the average tax rate will suffice.
  2. Corporate reality theory-Because a corporation is a legal entity that has rights and abilities that are independent of the individual, the corporation itself can be the taxpayer in terms of taxation. Therefore, the tax rate should be a progressive tax rate because corporations have different tax-bearing powers as well as individuals. Furthermore, there is no double economic taxation between corporate income tax and personal income tax, and there is no need to take cease and desist measures.

The corporate fiction theory and the corporate reality theory are said to be similar to the corporate fiction theory and the corporate reality theory in the Civil Code.[6], The discussion of the corporate imitation theory and the corporate reality theory regarding corporate tax is just a tax discussion and is not the same as each position in the Civil Code.[7].. These discussions are discussed from a tax policy perspective, and there are criticisms about bringing in civil law discussions.[8], It may be organized by the classification of the shareholder collective theory and the corporate independent taxable entity theory.[6].

Corporate tax and income tax

Regarding the nature of corporate tax, there is a debate over the relationship between taxation of corporations and taxation of their members (shareholders).[6].

Double taxation debate

Yoichi Takahashi pointed out that "taxing the internal reserves of a corporation while taxing the personal assets of shareholders is clearly a double taxation from a theoretical point of view. This may hinder economic activities." Are[9].

Kikuo Iwata said, "Corporate tax levied on corporate income is taxed on shareholders'income. Dividend income tax is double taxed because it is taxed on shareholders' dividend income from income after corporate income tax." Pointed out[10].

EconomistToshiyuki Uemura"Shareholders will be double taxed if they receive dividends after corporate tax is levied and dividend income tax is levied. Therefore, it is necessary to adjust double taxation for dividends by corporate tax and income tax." doing[11].. However, Uemura points out that "if the stock market is functioning normally, retained earnings will not lead to a rise in stock prices and profits for shareholders, and corporate tax will not be borne by shareholders."[12].

Hiroko Ota said, "If you raise funds with corporate bonds and borrowings, the interest rate will be deducted and tax exempt, so creditors will have an advantage over shareholders. To completely adjust double taxation,Imputation methodIt is necessary to take complicated measures. "[13].

Yoichi Takahashi said, "Corporate tax is not necessary in principle because it is double taxation if the supplement of income tax and property tax is perfect. The high corporate tax rate in Japan is the understanding of individual assets and income. Is insufficient (Croyon) Can be said to be the result.Taxpayer identification systemIf it can be introduced, there is a possibility that income tax and other revenues will increase. It is rational in terms of tax theory to use the increased revenue to reduce corporate tax. "[14].. Takahashi said, "The reason why corporate taxes are being reduced in each country is that the development of IT and laws has made it possible to supplement individual assets and income with high accuracy. Japan should also reduce it without considering such circumstances. Is a mistake. "[15].

Relationship between corporate tax and income tax

There are two views on the nature of corporate tax:[6][16].

  1. Corporate Independent Taxation Subject Theory-A corporation has its own tax-bearing power as a socio-economic entity independent of an individual, and itself receives services from the state and incurs social costs.[17].. In theory, the problem of double taxation with income tax does not occur.
  2. Shareholders' collective theory-Corporate tax is regarded as a prepayment of income tax, assuming that a corporation is merely a conduit for income and ultimately belongs to its members through dividends and refunds of equity.[6](Supplement to personal income tax). It is in line with the historical background that corporate tax was separated from income tax. If there is a shareholder who has received a dividend from a corporation after corporate tax taxation, imposing income tax on that shareholder is a double taxation of corporate tax and income tax. Double taxation of corporate tax and income tax should be eliminated or relaxed as much as possible[6]

However, for a real corporation,Separation of ownership and managementBecause it is premised on, the actual situation is the same as that of a private company (Incorporation), And there are some aspects that cannot be divided unconditionally. Also, the burden of corporate tax does not extend to the corporation itself.consumer-Worker-ShareholderIt is passed on to. In this way, corporate tax is not a self-contained tax system, so it is necessary to make it consistent with income tax (integration of corporate tax and income tax).

Integration of corporate tax and income tax

Several methods have been devised to ensure that corporate tax and income tax are consistent.[18].

Full integration

A method of treating all corporate income as belonging to shareholders under tax law. It is premised on the elimination of corporate tax.

  • Union method (pass through)
Corporatecombination(Civil law), And corporate income is attributed to shareholders (proportional distribution) according to the shareholders' equity, and tax is levied according to the amount attributed. It is also called pass-through because profits and losses pass through the corporation (pass thorogh).
Both executors and taxpayers are technically difficult to tax income that has not been realized in reality.
Partial integration

A method of adjusting only the dividend portion of company income with income tax.

  • Corporate tax Shareholder attribution method (imputation method)
Income tax amount calculated by attribution and addition of corporate tax amount to shareholders according to dividend incomeProgressive tax rateAnd then deduct the added corporate tax amount. Imputation here refers to the attribution of income that originally belongs to a company to the shareholders.
Adjustment at the shareholder stage. We regard corporate tax as a pre-emption of income tax on dividends received. It is designed to approximate the case where shareholders themselves earn income. It is said to be an elaborate integration method.
It was adopted in Western countries in the 1970s, but was abolished after 1990.
  • Dividend income deduction method
A method of deducting a part (a certain percentage or a certain amount) of dividends received by shareholders from the amount of income tax.
Adjustment at the shareholder stage. Rough integration. The higher the income, the greater the reduction in tax burden.
  • Dividend tax credit method
A method of deducting a part (a certain percentage or a certain amount) of dividends received by shareholders in the process of calculating the tax base of income tax.
Adjustment at the shareholder stage. A rough method compared to the corporate tax shareholder attribution method. JapaneseDividend deductionAdopts this method.
  • Dividend loss entry method
A method of deducting the portion of corporate income allocated to dividends from corporate tax.
Adjustment at the corporate stage. Double taxation can be eliminated for dividends. This is a pay-through to a special purpose company.
  • Double taxation method
A method in which a tax rate lower than the normal corporate tax rate is applied to the dividend portion of corporate income.
Adjustment at the corporate stage. This is a rough method compared to the payment dividend loss entry method.
Correspondence of each country

As of 2014, no country has a complete integration of income tax and corporate tax. However, some countries have taken some special measures to alleviate the problem of double taxation.[19].

1950 yearsShoup RecommendationByDividend deductionWas proposed and introduced into the Japanese Income Tax Act (Shaup tax system).Dividend incomeA mechanism to deduct the amount of decrease in dividends due to corporate tax from the amount of income tax on. In addition to this, the dividend income for large shareholders分離Amendments have been made by the Special Taxation Measures Law, such as (Article 8-4, Paragraph 1 of the Special Taxation Measures Law) and exemption from filing tax returns for shareholders with small dividends (Article 8-5 of the same).
There are few special rules for the integration of corporate tax and income tax.
Since the tax reform in the 1970s, the corporate tax shareholder attribution method has been adopted. However, it was difficult to have relationships with foreign corporations and shareholders, and in the 1990sEuropean Court of JusticeAfter deciding that it was a violation, the tide went down. Instead, move to a rougher tax system.

tax rate

The tax rates of each OECD country are as follows.

CountryCorporate income taxes
dividendtax rate
Integrated corporate tax rate
Irish flag ã‚¢ã‚¤ãƒ«ãƒ©ãƒ³ãƒ‰12.5%51.0%57.1%
Republic of Korea flag  South Korea27.5%40.3%56.7%
Canadian flag ã‚«ãƒŠãƒ€26.8%39.3%55.6%
French flag France32.0%34.0%55.1%
Danish flag ãƒ‡ãƒ³ãƒžãƒ¼ã‚¯22.0%42.0%54.8%
Belgian flag ãƒ™ãƒ«ã‚®ãƒ¼29.6%30.0%50.7%
Portugal flag Portugal31.5%28.0%50.7%
British flag The United Kingdom19.0%38.1%49.9%
Israeli flag ã‚¤ ス ラ エ ル23.0%33.0%48.4%
German flag Germany29.9%26.4%48.4%
United States flag America25.9%29.3%47.6%
Australian flag Australia30.0%24.3%47.0%
Norway flag ãƒŽãƒ«ã‚¦ã‚§ãƒ¼22.0%31.7%46.7%
Austrian flag ã‚ªãƒ¼ã‚¹ãƒˆãƒªã‚¢25.0%27.5%45.6%
Swedish flag ã‚¹ã‚¦ã‚§ãƒ¼ãƒ‡ãƒ³21.4%30.0%45.0%
Japanese flag Japan29.7%20.3%44.0%
Italian flag ã‚¤ã‚¿ãƒªã‚¢24.0%26.0%43.8%
Dutch flag  Netherlands25.0%25.0%43.8%
Finnish flag ãƒ•ã‚£ãƒ³ãƒ©ãƒ³ãƒ‰20.0%28.9%43.1%
Spanish flag ã‚¹ãƒšã‚¤ãƒ³25.0%23.0%42.3%
Mexican flag ãƒ¡ã‚­ã‚·ã‚³30.0%17.1%42.0%
Luxembourg flag Luxembourg24.9%21.0%40.7%
Flag of Slovenia ã‚¹ãƒ­ãƒ™ãƒ‹ã‚¢19.0%25.0%39.3%
Greek flag Greece28.0%15.0%38.8%
Swiss flag ã‚¹ã‚¤ã‚¹21.1%21.1%37.8%
Iceland flag ã‚¢ã‚¤ã‚¹ ランド20.0%22.0%37.6%
Chilean flag ãƒãƒª25.0%13.3%35.0%
Turkish flag ãƒˆãƒ«ã‚³22.0%17.5%35.0%
Polish flag ãƒãƒ¼ãƒ©ãƒ³ãƒ‰19.0%19.0%34.4%
New Zealand flag New Zealand28.0%6.9%33.0%
Czech flag ãƒ ェ コ19.0%15.0%31.2%
Lithuanian flag ãƒªãƒˆã‚¢ãƒ‹ã‚¢15.0%15.0%27.8%
Flag of Slovakia Eur-lex.europa.eu eur-lex.europa.eu21.0%7.0%26.5%
Hungarian flag ãƒãƒ³ã‚¬ãƒªãƒ¼9.0%15.0%22.7%
Estonia flag ã‚¨ã‚¹ãƒˆãƒ‹ã‚¢20.0%0.0%20.0%
Latvian flag ãƒ©ãƒˆãƒ“ã‚¢20.0%0.0%20.0%
  • UK income tax includes corporate tax and income tax, which are national taxes levied by the central government.[22].
  • Dutch income tax includes corporate tax, income tax and wage tax, which are national taxes levied by the central government.[22].
  • Sweden has a national personal and corporate income tax as an income tax[22].
  • Corporate tax is a federal and state joint tax in Germany[22].
  • In the United States, there are federal corporate income tax and state government corporate income tax as income tax. The federal corporate tax is 21%, but the state corporate tax varies from state to state. Some states are tax-free, such as Nevada and Delaware[22].
  • Canada also has federal corporate income tax and state government corporate income tax as income tax, but the federal government often collects corporate income tax according to the tax collection agreement between the federal government and the state government.[22].

Japanese corporate tax

JapanCorporate tax is mainlyCorporate tax lawAlthough it is stipulated in (Law No. 40 of 34),Tax Special Measures ActAnd will be amended by special laws such as the Earthquake Special Law.

In Japan, the tax on corporate income of a corporation is the national tax, corporate tax.Local corporation tax, National tax but collected by local governmentLocal corporation special tax(Until September 2019)Special corporate business tax(From October 2019),Local taxMinutesCorporate business taxとCorporate resident taxAnd are affected by these taxes, corporationsStatutory effective tax rateThe sum of national tax and local tax is levied[24].. (See each page for details.)


Initially, Japanese corporate tax is levied on corporationsincome taxIntroduced as a kind ofMeiji32 years (1899) ofIncome tax lawIt is derived from the first-class income (corporate income tax) newly established by the revision.Showa15 years (1940), The income tax on corporations was separated (establishment of the Corporation Tax Law).

High economic growthIt played the role of a core tax in the times,Bubble economyAround that time, he was overtaken by income tax revenue and is gradually lowering his position. But,1980 eraSignificant income tax cut from (about 30%),Bubble burstLater economic downturn,1990 eraThe second half of theFinancial crisisAfterRecessionDue to sluggish employment compensation,Fixed rate tax reductionIncome tax revenue has decreased significantly due to the introduction of1991(Heisei3 years): 26.7 trillion yen →2006(18): 14.1 trillion yen),2003From (15)Quantitative monetary easing policyIn 2006 (Heisei 18) due to strong exports1988It became the number one tax revenue item since (63).2007The ratio of national tax to tax revenue (19) is second only to income tax.2008(20)Global recessionIn the supplementary budget, it was second in the supplementary budget.2009In the budget for (21), it is almost the same as the consumption tax.[25].

In addition,2002From (Heisei 14)subsidiaryFor the purpose of transferring profits to, etc. and hiding lossesOff-balance sheet debtTo preventConsolidated tax paymentThe system was introduced, and a system was established in which group companies can pay corporate tax based on their consolidated business performance. Some corporate groups have become able to save taxes. In addition, IT investment promotion tax system (IT investment tax reduction,2005R & D promotion tax system (R & D tax reduction) has been established, and corporate IT investment and R & DIncentiveIt has become. 2011% (national tax) in Japan in 40.69[26] The tax has been reduced from 27.89, local tax 12.80) to 35.64% (national tax 23.71, local tax 11.93).[24].

Japan as of 2015Effective corporate tax rateIs 32.11%,Japanese govermentTo enhance the international competitiveness of companies as "Growth-oriented corporate tax reformWas started and reduced to 2016% in FY29.97.[27], To companies as an alternative source of revenueCapital investmentIt was decided to reduce the scale of tax cuts (review from FY2016 to narrow the range of expenses that can be recorded).

According to a survey by the Ministry of Economy, Trade and Industry in July 2017, 7 Japanese companies are booming, such as returning to Japan from overseas in just one year in 724 by comparing with overseas production costs. Professor Kim Jong-sik explained that the Japanese government's corporate tax cuts, yen depreciation, regulatory reforms, and equipment automation have made products manufactured in Japan more internationally competitive in terms of costs. In Yorii Town, Honda's return to the home country of manufacturing from Mexico has enriched the entire surrounding area with employment, large-scale consumption and capital investment. It was reported that small and medium-sized companies are returning to Japan one after another.[28].

Taxable person

  1. Domestic corporationIs obliged to pay taxes on its worldwide income. However, of the domestic corporationsPublic interest corporations, etc.,Associations without personality, etc.about,Profitable business, Obliged to pay tax only when operating a corporate taxation trust or retirement pension business (Corporate Tax Law, Article 4).
  2. Foreign corporationsDomestic source incomeYou will be obliged to pay taxes when you have a retirement pension service. However, among foreign corporations, public interest corporations or associations without personalityDomestic source incomeWe are obliged to pay tax only when there is something that arises from profitable business (Corporate Tax Law, Article 4).
  3. Public corporationIs not obliged to pay tax regardless of 1 above (Corporate Tax Law, Article 4).

Scope of taxation

Corporate tax is levied on the following three categories.

  1. Corporate tax on income for each fiscal year
  2. Income tax on consolidated income for each consolidated fiscal year
  3. Corporate tax on retirement pension reserves


Corporate tax is levied on corporate income. Based on commercial lawCorporate accountingIn the final settlement, income and expenses are the main items of settlement, while in tax accounting, which calculates corporate tax based on the tax law, income, loss, and profit are the main items. Revenue is income minus non-deductible and deductible, and deduction is expense minus non-deductible and deductible. Income is the difference when the profit is larger than the loss, and when the profit is smaller than the loss, it is in the red.

Revenue --Not included in profit + Included in profit = Profit
cost --Not deductible + Deductible = Deductible
Profit - Loss = Income (However, if profit> loss)
income × tax rate = Tax amount

However, tax returns are adjusted for profits when calculating profits and for expenses when calculating losses, and income deductions are excluded when deducting tax.Tax creditThere is[29].

Tax return and payment

  • Final return
    • Within two months from the day following the end of each business year, a final tax return must be submitted to the tax office chief based on the finalized settlement of accounts (Corporate Tax Law, Article 2).
    • If it is deemed that the final tax return cannot be submitted by the deadline because the settlement of accounts is not finalized due to having to be audited by the accounting auditor, an accounting auditor will be appointed for one month. Therefore, if it is recognized that the ordinary general meeting cannot be convened within 1 months from the end of the business year according to the articles of incorporation, the deadline for submission can be extended up to April (Article 3-4 of the Corporate Tax Law). ). Interest tax will be levied on the extended period (if there is no expected payment).
  • Interim return
    • If the business year exceeds 6 months, an interim tax return must be submitted to the tax office chief within 6 months from the date 2 months after the start of the business year. However, it is not necessary under some conditions such as the amount of corporate tax paid in the previous year was 20 yen or less.
  • Correction report
    • You can file a correction within the legal filing deadline. If you send the document in the same format again, the last one sent will be automatically adopted and it will be a correction report.[30].. In the case of the second payment, if the payment amount increases, only the difference needs to be paid.
  • Declaration after the deadline
    • Even if you do not submit your tax return by the deadline for filing your tax return, you can still submit your tax return late (Article 18 of the General Rules for National Taxes). As a general rule, undeclared additional tax is levied.
  • payment
  • Amendment declaration
    • If the tax amount stated in the final tax return is too small or the loss carried forward is reduced, an amended tax return can be submitted even after the statutory filing deadline (Article 19 of the General Rules for National Taxes). As a general rule, underreporting additional tax will be levied if submitted after being investigated by the tax office.[31].. Underreporting additional tax will be levied using a different formula even if you file an amendment after prior notice of the tax office's investigation and before the tax office's investigation. If you submit the amended tax return and do not pay it on the same day, you will be charged a late tax from the next day.
  • Request for rectification
    • If the tax amount stated in the final tax return is too large or the loss carried forward increases, it is limited to within 5 years from the statutory filing deadline, and if the loss carried forward increases, it is limited to within 9 years (there are many other small exceptions). , You can submit a tax return for correction (Article 23 of the General Rules for National Taxes).

Corporate tax rate

Fiscal year starting on or after April 30, 4[32]
Classification of corporationOf the amount of income
Amount of the portion of 800 million yen or less per year
Of the amount of income
Amount of the portion exceeding 800 million yen a year
Of the amount of income
Amount of the portion exceeding 10 billion yen per year
Ordinary corporation (other than small and medium-sized corporation)23.2%23.2%23.2%
Small and medium-sized corporations (ordinary corporations with year-end capital of 1 million yen or less)
What is regarded as a public interest corporation, etc.
Associations without personality, etc.
Public interest corporationWait
specificMedical Corporation
Cooperatives, etc. or consolidated parent corporations that are specific medical corporations16%20%20%
Specified cooperatives with more than 50 members and store sales of 1,000 billion yen or more (large-scale co-op)15%19%22%
Public corporation0%0%0%
Changes in corporate tax rate
年度tax rateOf Tokyo
External standard taxable corporation
Statutory effective tax rate
2003In corporate enterprise tax for corporations with capital of over 1 million yen
External standard taxationIntroduced (to collect taxes even in the red)
2009Local corporation special tax newly established
201225.5%. However, 2014% of reconstruction special corporate tax will be added until FY10.38.01%[Annotation 1]
2014Reconstruction special corporate tax ends35.64%[Annotation 2]
201523.9%. New local corporate tax33.10%
201623.4%30.86%[Annotation 3]
201823.2%30.62%[Annotation 4]
2020Local corporation special tax abolished
Special corporate enterprise tax newly established

The fiscal year is assumed to be a corporation that closes at the end of March. The above tax rates are national tax and corporate tax only. In addition, corporations are against incomeLocal corporation tax(From October 2014) ・Corporate resident tax-Corporate business tax-Local corporation special tax(October 2008-September 10) ・Special corporate business tax(From October 2019) It will take. Based on theseStatutory effective tax rateIs calculated. Since the local tax rate varies from region to region, the statutory effective tax rate varies from region to region.

Tax adjustment according to company size

Tax burdenThe corporation tax and its peripheral laws are used to make adjustments according to the size of the corporation, taking into consideration the problems of

For example, for small and medium-sized enterprises, light tax rates, expansion of deduction limits, deferral of taxation, etc.Tax creditPreferential adjustment such asTax Special Measures ActIs in[33].

In addition, local tax (corporation)Prefectural tax·CorporationBusiness tax(External standard taxation) is taxed according to the size of the corporation from the standpoint of the existence of the corporation, so it can be said that it is a heavy tax for large companies.

Loss carried forward

In the case of a company that has a deficit (deficit), if a blue declaration is submitted, in principle, 50% to 100% of the deficit can be carried over and offset with income. How much you can carry over is stipulated by the size of the company etc.[34].

The number of years that can be carried over is as follows.

  • Five years for business years started before March 13, 3
  • 13 years for business years started on or after April 4, 1[35]
  • 20 years for business years ended after April 4, 1
  • 30 years for business years started on or after April 4, 1[36]

For example, in the case of a corporation with a settlement of accounts at the end of March, it will be as follows.

  • Settlement at the end of March 27: 3 years from the end of March 20 to the end of March 3
  • Settlement at the end of March 28: 3 years from the end of March 21 to the end of March 3
  • Settlement at the end of March 29: 3 years from the end of March 21 to the end of March 3
  • Settlement at the end of March 30: 3 years from the end of March 21 to the end of March 3
  • 平成31å¹´3月末決算:平成22å¹´3月末決算~平成30å¹´3月末決算の9年分(令和10å¹´3月末決算まで繰り越しは9年分)
  • Settlement at the end of March 11: 3 years from the end of March 31 to the end of March 3 (carryover will be 10 years from this year)

Loss carryforwards have been adopted in many countries, with Germany and the United Kingdom having an unlimited carryforward period.[37].

Changes in tax revenue

Treasury Statistics[38][39][40] See. Due to the shift from corporate tax to consumption tax, corporate tax sales decreased by 1988 trillion yen and consumption tax increased by 2017 trillion yen in 7 compared to 18, which was a record high.

Changes in corporate tax revenue and consumption tax revenue (national tax only)
年度Corporate tax revenueConsumption tax revenueSummary
198412.0 trillion yen0 Yen
198513.1 trillion yen0 Yen
198615.8 trillion yen0 YenBubble economyStart
198718.0 trillion yen0 Yen
198819.0 trillion yen0 Yen42% tax rate, record high corporate tax revenue
198918.4 trillion yen3.3 trillion yenTax rate 40%, consumption tax 3% introduced
199018.4 trillion yen4.6 trillion yenTax rate 37.5%
199116.6 trillion yen5.0 trillion yenBubble burst
199213.7 trillion yen5.6 trillion yen
199312.1 trillion yen5.6 trillion yen
199412.4 trillion yen5.6 trillion yenCabinet decision to raise consumption tax by XNUMX%[Annotation 5][41]
199513.7 trillion yen5.8 trillion yen
199614.5 trillion yen6.1 trillion yen
199713 million yen9 million yenConsumption tax increased to 5%
199811 million yen10 million yenTax rate 34.5%
199910 million yen10 million yenTax rate 30.0%
200011 million yen9 million yen
200110 million yen9 million yen
20029 million yen9 million yen
200310 million yen9 million yen
200411 million yen9 million yen
200513 million yen10 million yen
200614 million yen10 million yen
200714 million yen10 million yen
200810 trillion 106 billion yen9 million yen
20096 million yen9 million yen
20108 million yen10 million yen
20119 million yen10 million yen
20129 million yen10 million yen
201310 million yen10 million yen
201411 billion yen16 million yenConsumption tax increased to 8%
201510 million yen17 million yen
201610 billion yen17 million yen
201711 million yen17 million yen
201812 million yen17 million yen
201910 million yen18 million yenConsumption tax 2019% in October 10 (food, etc. remains at 10%)
202011 million yen20 million yen

Discussion in Japan

According to data from the Ministry of Finance, the effective tax rate in European countries such as France, Germany, and the United Kingdom is around 30%, and in South Korea and China, it is in the high 20% range. Japan's effective tax rate is as high as the United States (as of 2010).[42].. It is argued that a high corporate tax from an international perspective means high costs for companies operating in Japan and is not desirable from the perspective of international competitiveness.[43].

economic growth

EconomistKoichi HamadaRegarding Japanese corporate tax, "Leaving corporate tax as it is is basically negative for the Japanese economy. High corporate tax rates are hindering investment in Japan, and if it is reduced to the 20% level, Japan's capital market will change. Lowering corporate taxes will increase income. "[44].

Motoshige Ito points out that "the corporate tax burden rate, which is the corporate tax revenue divided by GDP, shows a higher index in Japan than in other countries, and the corporate tax burden is heavy."[45].. Ito said, "Even if the corporate tax rate is reduced (in Japan), it cannot be expected that the current (2013) Japanese companies, which have abundant internal funds and no liquidity restrictions, will promote investment. In the medium to long term (Japan) ) Companies may be subject to liquidity constraints, which will require a reduction in the average tax rate. "[46].

Yasushi Harada,Daiwa Institute of Research"A corporate tax cut of 1% of nominal GDP will raise real GDP by 2% in the second year. However, the effect of the corporate tax cut is a medium-term supply effect and is short-term like a macroeconomic model. There will be criticism that it cannot be analyzed by a method that emphasizes demand. "[47].

Regarding the view that Japanese corporations have a large tax burden when comparing GDP and corporate taxJurist OfYoshikazu MikiWhen comparing the total amount of corporate tax revenue with other countries, it is necessary to consider the actual situation of corporations that differ from country to country. Japan has about 225 million companies compared to about 260 million companies in the United States, which is Japan compared to the economic scale. Has more corporations (62-63 in Germany and Italy, 94 in France), and in Japan, even small and medium-sized enterprises are incorporated compared to the United States.[48].

EconomistRobert FeldmanNeeds not only to reduce the corporate tax rate, but also to adjust the social insurance burden and regulations to the same level as international standards. "[49].

Naohiko Jinno said, "Transformation of industrial structureIf we are aiming for economic growth based on this, reducing the effective corporate tax rate is not an effective means. In Japan, there is a need for spending policies that improve conditions for new industrial investment rather than tax cuts. "[50].

An economist points out that "Japan is lighter than European countries in terms of the total of corporate taxation and social insurance premiums paid by business owners" (as of 2005).[51].

According to the Ministry of Finance data, the number of corporations in Japan is 257 million, while it is 172 million in the United States, 183 million in the United Kingdom, and 88 in Germany.[52].

International competitiveness

Kikuo Iwata said, "The high corporate tax rate in Japan compared to other countries encourages the outflow of Japanese companies overseas and contributes to the hollowing out of domestic industry. It also prevents the influx of foreign companies. Will be. "[53].

EconomistYasushi Harada"It is difficult to reduce taxes in a huge budget deficit, but corporate tax reductions should be promoted. Since corporations can move anywhere, they will go to a country with a large share when they succeed. In such location competition We need to cut taxes so we don't lose. "[54].

Hiroko Ota says that reducing the corporate burden by reducing the effective corporate tax ratewage-investment-dividendTurn to. High corporate taxes will eventually affect households, and if Japan is not selected as a location, it will lead to employment reduction and wage restraint. "[55].

Motoshige Ito said, "From overseas to Japan.Direct investmentIs significantly lower than in other countries. High corporate tax rates are not the only cause, but it is clear that high tax rates are a major obstacle to investment. ”“ When a company invests abroad, the size of the market, human resources, political stability, and technology. It is judged from various factors such as the level. The corporate tax rate alone does not determine the location and investment amount. "[49].

Heizo Takenaka said, "While companies are moving forward with the location of factories overseas, such as in China, it is not a simple matter to say that tax measures alone will increase domestic investment. Considering finances, we will cut investment taxes to some extent. That is effective as a policy. "[56].

Naohiko Jinno said, "In a survey of companies outside Japan, high wages, strict quality, and language ability were pointed out as obstacles to investment in Japan, and the high tax burden is low. Effective. Even if the tax rate is reduced, investment such as establishing a factory will not proceed, and only investment such as takeover will occur. "[50].

Kazuhide Uekusa points out that "if the base of business activities moves overseas, the profits of the production activities of the tax source company will also move overseas."[57].

About the outflow of companies overseas Yukio Noguchi

  1. The most important factor for the manufacturing industry to decide the production base is the wage gap, not the corporate tax rate.
  2. Under international taxation principles, no matter where the factory is located, as long as the company brings the profits back to the country, the tax rate of that country will eventually be applied and the tax burden will not change.

Pointed out[58].

Andrew Smithers of Smithers & Company (UK) says that the low profit margins of Japanese companies are due to overinvestment, and it is necessary to reduce overinvestment and improve investment efficiency. .. In addition, the corporate tax system in Japan allows depreciation to be excessive, which is whyRetained earningsHe argues that a corporate tax cut will only worsen the national finances. Rather, if a tax system that suppresses corporate savings is implemented, wages and dividends will increase, and as a result, tax revenue will also increase.[59].

Business scholar OfTadao Kagono"Recently (2012), Japanese companies have been accumulating surplus funds. It is necessary to encourage corporate risk investment. To encourage Japanese companies to invest, it is not a simple corporate tax cut, but Investment tax cuts should be made. "[60].

Economists said, "Retained earnings of companies and large amounts of foreign investment are not something that the government can use on their own, because most of them are private. Even if we say that retained earnings of companies should be invested. The government can only guide it. Retained earnings of companiesdeflationIt is a product of the company, and if it stimulates domestic demand, it will be used for investment. "[61].

JETROAccording to a questionnaire survey conducted by foreign-affiliated companies in Japan, the top obstacles to doing business in Japan are (XNUMX) difficulty in securing human resources, (XNUMX) difficulty in communicating in foreign languages, and (XNUMX) high business costs. (XNUMX) Complexity of administrative procedures (XNUMX) Severity of the licensing system, etc. Regarding (XNUMX), the main factor is high office rent, labor costs, and hiring costs, and the tax rate itself is not a particularly high priority as an obstacle, and even if you are dissatisfied with tax payment, it is not the tax rate itself but the time required for tax payment procedures. It has been pointed out that the problems involved and the complexity of the tax payment system are problems.[62][63][64].. In addition, according to a questionnaire survey conducted by the Cabinet Office for Japanese manufacturing companies that have moved their production bases from Japan to overseas, the main reasons for the overseas move are low labor costs, expanding local demand, and responding to local needs. The overwhelming majority of the respondents said that they moved overseas due to preferential treatment such as local taxation and loans, because the overwhelming majority of the factors were that they entered the market with the advancement of parent companies and business partners.[65].. While the corporate tax rate in Japan has been declining for many years[66], The overseas local production ratio of the manufacturing industry has been rising for many years[67].

Impact on tax revenue

Shigeki Kunieda said, "The background is different between the EU and Japan. In Japan, tax revenues are decreasing due to the reduction of the corporate tax rate. The" corporate tax paradox ", in which tax revenues are stable even if the tax rate is lowered, It has not been established. This is because the individual business owner did not "become a corporation" just because the tax base was expanded and the corporate tax rate was lowered. "[68].

Naohiko Jinno said, "In the case of Japan, at the same time as the effective tax rate was reduced, the tax base was reduced rather than expanded. When reducing the effective tax rate, the tax base was reduced by reviewing special tax measures, loss carryforwards, dividends received, etc. It needs to be expanded. "[50].

Robert Alan Feldman said, "Reduction of corporate tax rate will not reduce tax revenue. Even if it decreases temporarily, it can be considered as an investment. If the reduction of corporate tax rate gives an incentive to start a business or develop technology, The economic growth rate will increase. As a result, tax revenues from consumption tax and income tax and social insurance premium income will also increase. "[49].

International Monetary FundThe (IMF) said that it is necessary to secure financial resources to prevent the increase in fiscal risk regarding the reduction of corporate tax in Japan. "By gradually reducing the corporate tax rate, fiscal risk The rise of the tax is suppressed. "[69].

Burden of SMEs and local companies

Hiroko Ota points out that "in Japan, the proportion of local corporate tax is high. Even though Japan is not a federal system, local corporate tax is heavy."[70].

Yoichi Takahashi points out that "reducing corporate tax and expanding the scope of external taxation is disadvantageous for small and medium-sized enterprises that do not have tax avoidance techniques. It will be criticized as preferential treatment for large enterprises."[71].

Other views

  • Koichi Hamada said, "Reducing corporate tax is important not only for industry and business, but also for the national economy. Corporate tax needs to be reduced not little by little, but significantly. For companies.Pollution tax-Tax Special Measures ActIn another way, such as the abolition ofFinancial reconstructionTo bear the burden of. It is the ego of the company itself that the corporate tax should be lowered and special measures should be left in favor of general remarks. " That may be the case, so to speak. "[72].
  • EconomistKumagai Ryomaru"(Japan) various special tax measures have become acquired rights in specific industries, distorting resource allocation between industries and commodities, and eroding the tax base of corporate tax. From now on, various taxes are not bound by acquired rights. It is necessary to verify the special measures from the viewpoint of "cost effectiveness" and to organize and integrate them. "[73].

Group claim

  • Japan Business FederationClaims that the high corporate tax rate in Japan has led to overseas transfers,Corporate tax is high and consumption tax is low in Japan[Source required]However, in reality, it is hard to say that discussions are being held from multiple angles, such as the ratio of consumption tax revenue to total tax revenue. In the United States, the consumption tax rate is basically zero, but in Europe and other countries, the corporate tax is lowered and the consumption tax is raised. As of 2007, Keidanren has a corporate tax.Statutory effective tax rateHas announced a recommendation to reduce the consumption tax by 30% and raise the consumption tax.[74].
  • The National Council has stated that the tax base and tax reduction measures for Japanese corporate tax differ depending on the country, so the tax burden of companies cannot be compared based on the surface tax rate alone, and the actual tax burden is stated.Securities reportCalculated from, in the case of large Japanese companies, it points out that the average of the top 100 companies with ordinary income is 30.7%, and criticizes Keidanren's proposal.[75].
  • Japan Communist PartyJapan has a tax incentive system mainly for large companies, and the actual burden rate is extremely low, with Sony's 12.9% at the top.[76][77], Reducing the corporate tax rate will only increase retained earnings[78], Insist.

Corporate tax and statutory execution rate of each country


20131Effective tax rate of corporate income taxation at the time (Legal execution rate) IsAmerica-CaliforniaIs 40.75% (national tax)[26] 31.91, local tax 8.84), Japan 35.64% (national tax 23.71, local tax 11.93),FranceIs 33.33% (national tax 33.33),GermanyIs 29.55% (national tax 15.83, local tax 13.65),People's Republic of China25.00% (national tax 25.00), South Korea 24.20% (national tax 22.00, local tax 2.20), UK 24.00% (national tax 24.00),SingaporeIs 17.00% (national tax 17.00) etc.[24].

As of January 2017, the statutory enforcement rate is 1% in the United States, 40.75% in France, and 33.33% in Japan.[Annotation 6](This figure is an area where corporate enterprise tax is the standard tax rate for corporations that are subject to external standard taxation. The tax rate is higher in Tokyo, etc.), Germany 29.79%, Canada 26.50%, People's Republic of China 25.00%, Italy 24.00 %, UK is 20.00%, etc.[27].. The Trump administration in the United States has stopped the overseas transfer of companies, and in order to lead to economic growth of 3% per year by increasing domestic employment and wages, income tax cuts for middle class and funds saved overseas by American companies Measures to encourage domestic investment by reducing the tax rate when bringing it back to Japan ・ The company has announced that it will reduce the current 35% corporate tax rate (federal tax) to 20%. The former Obama administration also aimed for a federal corporate tax rate of 28%, but failed. According to the U.S. government, the average corporate tax rate in industrialized countries around the world is less than 22.5%, so about 20% will increase the competitiveness of companies.[81]。2017年12月時点でアメリカの上院は法人税の最高税率35%を20%に引き下げる減税法案を可決した。イギリスは2017年12月時点の19%から17%へ、フランスは33.3%から25%に8.3%の推進している[82].

Branch of a foreign corporation

Amazon Japan Co., Ltd.Has not paid corporate tax to Japan. Amazon Japan does not sell products to Japanese corporationsThe United States of AmericaState of WashingtonSeattleIs headquartered inAmazon.com Int'l Sales, Inc.And the companyDoes not have a branch office in JapanWith thatNational Tax AgencyI have defended against. 2009,Tokyo National Taxation BureauHas some of the functions of a US corporation within the Amazon distribution center, which isCorporate tax law-US-Japan tax treatyStipulate inPermanent facilityAs2003から2005 [83] A tax of 140 billion yen was levied[84].. On the contraryAmazon.comThe side is 1 millionU.S. dollarThebankDeposited in[83].. After that, discussions were held between the US and Japanese authorities, and a final agreement was reached in September 2010 by rejecting the request of the Japanese National Tax Agency. NTA has released most of its bank deposits[83].. But Amazon's corporate tax is stillFrance-Germany-Luxembourg-The United KingdomIt has been pointed out that inspections are in progress or may be conducted by[83].

Corporate tax and economic and fiscal policy

Corporate tax and economic growth

economist OfPaul Krugman"Looking at the examples of other developed countries such as the United States, it seems that there is not much relation between corporate tax cuts and GDP growth."[85].

EconomistMotoshige Ito"The economy is a complex system, and how corporate tax rates change corporate behavior, which in turn affects employment and economic vitality.Macro economyWe need to think as a whole. "[86].. Motoshige Ito said, "It is necessary to look at not only corporate tax but also other taxes from a broad perspective on how much tax revenue the entire tax system will bring and how it will affect the economy as a whole." Pointing out[46].

Ito said, "If corporate activities are activated by reducing the corporate tax rate, the benefits will spread to the entire nation. The view that the benefits of reducing the corporate tax rate are only for some large companies that are making a profit is not correct. Corporate tax Tax cuts make a company's cash on hand more abundant, which can be used as a company's investment fund. "[46]¡Ito said, "Many Asian countries are aggressively lowering corporate tax rates. There may be an aim to attract more investment from overseas, but that is not the only reason for lowering corporate tax rates. Corporate tax rates. It is effective in revitalizing economic activity to keep the tax rate as low as possible.economic growthThe underlying view is that it works in a big positive way. "[46].

Hiroko OhtaIs "AmericanRonald ReaganIn the first tax reform in 1981, the president introduced a policy tax system that changes the way capital investment tax reduction and depreciation are carried out. In the second tax reform in 1, the corporate tax rate was reduced by 1986%. This reform laid the groundwork for new IT-related businesses in the 2s. "[70].Shigeki Morinobu"There is a fact that the changes in the industrial structure of the US economy caused by the tax reform of Reagan's second term led to the later economic prosperity."[87].

Corporate tax and tax revenue

The "corporate tax paradox" refers to the phenomenon that corporate tax revenue increases as the effective tax rate is lowered.[50][88].

Motoshige Ito points out that "European countries have lowered the statutory corporate tax rate, but tax revenues are increasing rather than decreasing."[46]¡Motoshige Ito is one of the factors behind the increase in corporate tax revenue in Europe.

  1. Improved corporate profits
  2. Expansion of tax base at the same time as the government reduced the corporate tax rate
  3. Due to the decrease in the corporate tax rate, individual companies have become corporations, and taxes are now paid by corporate tax instead of income tax.

Listed three[89].

Motoshige Ito said, "Even if the corporate tax rate is lowered, if the tax base is expanded, the corporate tax revenue will not decrease. In some cases, it may increase. For that purpose, at the same time as lowering the corporate tax rate, We should consider expanding the tax base. "[46]¡Ito said, "In some countries, such as Germany, the corporate tax rate has been lowered and other tax reduction measures have been reduced (expansion of the tax base), but economic growth has resulted in corporate tax revenue despite the reduction of the tax rate without such measures. In some countries, it has led to growth. "[90].

EconomistFumio Otake"It is not clear to what extent corporate tax revenues will increase due to corporate tax cuts, except for the effect of an accidental economic recovery. In some countries, the corporate tax paradox has not been observed. One of them is Japan. In the 1990s, corporate tax in Japan fell and corporate tax revenue fell at the same time. "[88].

Corporate tax and international competitiveness

EconomistNorihisa Iwata"The development of the global economy since 1990 has led companies to decide their location from a global perspective, and corporate tax is one of the major costs of choosing a corporate location." "Under the global economy In the long run, corporations will try to move their production bases from countries with high corporate tax rates to countries with low corporate tax rates. The proportion will increase. "[53].

Motoshige Ito said, "If the corporate tax rate is reduced by 1 percentage point, the results will vary depending on the country, survey period, and analysis method, but it is expected that investment will increase by about 2-4%, and some investment. Expected to have an inducing effect. "[49].

An economist points out, "If you lower the corporate tax rate, capital will flow in from abroad. In Europe, the benefits are great in small economies such as Ireland and in Asia, Hong Kong and Singapore."[68]On the other hand, Kunieda pointed out, "In a country with a large economy such as Japan and the United States, considering the scale of GDP, it is difficult for capital to flow in and tax revenue to increase by lowering the tax rate." ing[68].

Economists on curbing investment activityYukio Noguchi"If the profit increases due to investment, the corporate tax will increase, but the interest on the loan will be deducted, so the corporate tax will decrease. After all, when investing by borrowing, the two effects will be offset and the corporate tax burden will be It won't change. "[58].

As one of the international competitions to attract companies, the competition to reduce the corporate tax rate (and raise the consumption tax at the same time) is in progress in Europe and other regions.WTOPointed out the problem as "harmful tax competition" and is discussing the framework in the international community.[91].

The corporate tax itself, which is a national tax, is about 0.3% higher in the UK than in Japan, but business tax and inhabitant tax, etc.Local taxIt is a tax rate that the company actually bears, includingStatutory effective tax rateCompared to the UK, the UK is 11% lower, and countries around the world are competing for tax cuts to prevent the outflow of companies and attract excellent foreign companies.[24][79][92].. Each country will reduce corporate tax in an era when companies choose the country to invest in, and even if corporate tax revenue decreases temporarily, by attracting companies and factories, domestic economic revitalization and domestic investment by companies will be promoted. This is because tax revenue will increase in the long run.[82].. Many Japanese companies have begun to do so since 2015 as the international competitiveness of Japanese manufactured products has become stronger due to corporate tax cuts, yen depreciation, regulatory reforms, and equipment automation.[28].

Hiroko Ota says that corporate tax is under pressure for a major shift.

  1. With the diversification of corporate activities and the need for international strategies, it is necessary to ensure that taxes do not distort corporate choices.
  2. As companies are in an era of easy global economic activity, we must be aware of international standards in taxes.
  3. International arrangements are becoming more important as the global expansion of companies makes tax collection difficult.

Pointed out[93].. Daejeon points out that "the burden of corporate tax is determined not only by the tax rate but also by the" tax rate "and" tax base "."[94].

Yukio Noguchi is a corporationTax systemEtc. vary from country to countryTaxationincomeOf the statutory effective tax rate withindexThe comparison doesn't make much sense[95].


[How to use footnotes]

注 釈

  1. ^ (25.5% * ((100% + 10%) + 20.7%) + (3.26% + 2.9% * 148%)) / (100% + 3.26% + 2.9% * 148%)
  2. ^ (25.5% * (100% + 20.7%) + (3.26% + 2.9% * 148%)) / (100% + 3.26% + 2.9% * 148%)
  3. ^ (23.4% + 23.4% * (4.4% + 16.3%) + (0.88% + 0.7% * 414.2%)) / (100% + 0.88% + 0.7% * 414.2%). Corporate tax = 23.4%, local corporate tax = 4.4%, corporate inhabitant tax = 16.3%, corporate business tax excess tax rate = 0.88%, corporate business tax standard tax rate = 0.7% (used to calculate local corporate special tax), local corporation Special tax = 414.2%
  4. ^ (23.2% + 23.2% * (4.4% + 16.3%) + (0.88% + 0.7% * 414.2%)) / (100% + 0.88% + 0.7% * 414.2%). Corporate tax = 23.2%, local corporate tax = 4.4%, corporate inhabitant tax = 16.3%, corporate business tax excess tax rate = 0.88%, corporate business tax standard tax rate = 0.7% (used to calculate local corporate special tax), local corporation Special tax = 414.2%
  5. ^ Japanese Socialist PartyIn the case of 6 years ago15rd House of Councilors ordinary electionThen, I was victorious against the consumption tax, but the Socialist PartyMurayama Tomi CityThe Prime Minister said that the consumption tax, which had been 1% until then, was reduced to 5,000% in 3 in a way that was commensurate with the tax reduction of about 3 trillion yen in order to reduce the fixed rate tax to the middle class for economic measures by 1997 trillion for three years. The law was passed. Of the 5% tax increase, XNUMX% was the local consumption tax.
  6. ^ As of 28 and 29. 25% as of 37, 30% in 29.74.


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  90. ^ [Thinking about the future of Japan] Professor Motoshige Ito, University of Tokyo Points of corporate tax revision + (1/2 page) MSN Sankei News March 2014, 2
  91. ^ Miki (2012), pp. 58-60
  92. ^ Effective tax rate (tax affairs)
  93. ^ Hiroko Ota, "Good Tax Increase, Bad Tax Increase-Aiming for a Convincing Tax System," Toyo Keizai, 2002, pp. 136-137.
  94. ^ Hiroko Ota, "Good Tax Increase, Bad Tax Increase-Aiming for a Convincing Tax System," Toyo Keizai, 2002, p. 137.
  95. ^ The burden of corporate tax in Japan is not heavy Yukio Noguchi --DAIAMOND online (June 2013, 6) Diamond.

Reference books

  • Yoshikazu Miki, "Japanese Taxes", 2012st edition published on March 3, 22, Iwanami Shoten,ISBN 9784004313595

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