Doing business in Japan What to know about taxation

Transcription

1

2 Doing business in Japan What to know about taxation Hans-Peter Musahl, Jürgen Dumont EY Tax Co, 30 May 2017 Webinar for Wirtschaftskammer Österreich Außenwirtschaftscenter Tokio

3 Table of contents I. Introduction to taxation in Japan II. Proposed Austria - Japan tax treaty III. Taxation of Austrian businesses in absence of a Japanese subsidiary, JV or branch 1. Export of goods 2. Provision of services 3. E-Commerce IV. Tax administration process V. Corporate income taxation VI. Japan tax reform 2017 VII. Transfer pricing and BEPS VIII. Indirect taxes IX. Overview of individual income and inheritance tax X. Tax controversy Speakers and contacts Page 3

4 Introduction to taxation in Japan and Japan basic economic data > 250% GDP-national debt ratio, reliance on direct taxes 0.2% Inflation (target: 2%), wage increase incentives Jobs-to-applicant ratio : 1.43/1 (unemployment rate: 2.8% ) Self assessment, short filing periods Corporate Tax: 30% - 35%; Enterprise Tax on Capital etc. Income Tax: 0% - 15% - 55% (first 5 years Japan source only) Inheritance and Gift Tax: 0% - 10% - 55%, Exit Tax: 15,3% Asset filing and disclosure Page 4

5 II. Proposed Austria - Japan tax treaty Page 5

6 Proposed Austria - Japan tax treaty announced by the Japan Ministry of Finance in 1/2017 Old treaty New treaty Dividends Parent-subsidiary (shareholding in %) 10% (holding at least 50% for 12 month) 0% (holding at least 10% for 6 month) Other Interest Royalties Capital gains AOA (internal dealings) Anti- avoidance 20% 10% 10% 25/5 rule N/A N/A 10% 0% 0% Resident, unless private real estate co Recogniz ed LOB PPT Introduction of a fiscally transparent entity concept (Art. 1 para 2) Residence and tie-breaker rule for individuals of both states (Art. 4 para 2) Introduction of AOA on the determination of the income attributable to a PE (Art.7 para 2) Source country taxation of capital gain on certain real estate holding companies (Art. 13 para 2) Objective and principal purpose tests for the entitlement of benefits (Art. 22) LOB: shareholder must be an individual or listed shareholder or, in case of a private co > 75% held Mandatory arbitration in mutual agreement procedures (Art. 25 para 5) Assistance in the collection of Japanese inheritance and gift tax (Art. 27 para 2, letter (b) (v) and (vi) Page 6

7 III. Taxation of Austrian businesses in absence of a Japanese subsidiary, JV or branch Page 7

8 Taxation of Austrian businesses in absence of a Japanese subsidiary, JV or branch 1. Export of goods Solely taxable in Austria, unless through a branch or dependent agent 2. Provision of services No withholding tax on services, 10% (future 0%) on royalties Service PE? 8% Consumption Tax, possibly exempt for 2 years 3. E-Commerce (differentiation between): B2B, where the reverse charge method will be applicable, for taxpayers with less than 95% taxable sales ratio (e.g. banks) Cross-border Digital Services (B to C), where the foreign service provider will be subject to Consumption Tax payment obligation, if for two years the taxable sales exceed 10 mil JPY p.a. Foreign provider must be registered and comply with two months filing period, etc. Page 8

9 IV. Tax administration process Page 9

10 Tax administration process in Japan Compliance and filing deadlines Annual corporate tax returns (including inhabitants & enterprise tax) To be filed within two months of the end of the corporation s fiscal year, tax return filing extension by one month (up to 4 months under tax reform 2017) Annual consumption tax returns: two months after FY-end, no extension Income Tax: Filing by March 15 Japanese tax return filing is based on a self-assessment system Each taxpayer calculates and files his taxes and related tax returns No immediate assessment of the tax returns and taxes by the authorities but regular audit cycle depending on undisclosed terms, e.g. size Heavy penalties for late and incorrect filings Quick tax administration procedures Filing period, statute of limitation, tax audit frequency Page 10

11 Corporate taxes (Overview) Blue Tax Return - Filing Blue Tax Return - Filing Qualifies corporations for special privileges, most importantly the ability to carry forward 55% of its losses for 9 years (up to 50% for FY starting 2018 ff) To receive permission to file a Blue Tax Return, a corporation must: Record transactions in books and maintain and preserve those books and records, and Submit an application with the head tax office before the beginning of the year for which the Blue Tax Return is to be filed Approval to file Blue Tax Returns can be revoked for: Not maintaining, recording or preserving books and other documents in accordance with tax laws, or Concealing or disguising all or part of transactions in the books of the account, or Failing to file tax returns by the deadline for two or more consecutive years Page 11

12 Extension of filing deadline under the tax reform 2017 Extension of filing deadline Extension Current NEW Requirements Extended period Financial statements cannot be closed because of the requirement to have an accounting audit etc. Generally one month extension Filing deadline is three months after the fiscal yearend 1. The company has an accounting audit and 2. The annual shareholders meeting cannot be held within 3 months after the fiscal year-end due to the articles of incorporation Up to four months extension Filing deadline can be extended to the end of the month of the shareholders meeting (six months after the fiscal yearend at the latest) End of Dec End of Feb End of Mar Shareholders meeting End of June Financial Yearend Statutory deadline (Current) Extended deadline (NEW) Extended deadline Page 12

13 V. Corporate income taxation Page 13

14 Reduction in effective corporate tax rates Large company eff. tax rate (standard) Large company eff. tax rate (metro.) SME effective tax rate (standard) SME effective tax rate (metro.) Old Tax reform 2016 CY / / / % 29.97% 29.74% 33.16% 32%* 31%* 33.5% 33.8% 33.6% 34.5% 34.8% 34.6% Tax Base Current ff salaries, rent, interest - metropolitan areas 0.504% 0.864% 1.152% salaries, rent, interest - standard rate 0.48% 0.72% 0.96% capital levy - metropolitan areas 0.21% 0.36% 0.48% capital levy - standard rate 0.2% 0.3% 0.4% Page 14

15 Tax loss carry forward (NOL) limitation and minimum taxation Deductible amount Carryforwar d period Qualified small and medium-sized corporations ( SME ), TMK, J-REITS etc. 100% of taxable income before NOL 9Yrs NOL limitation Companies whose parent co ies have > 500 mil JPY share capital 55% of taxable income before NOL 9Yrs Deductible amount Carryforward period From CY % of taxable income before NOL 10Yrs Minimum taxation rule allowing to set off losses against only 55% of current year income (from FY 2018 on: only 50%) SMEs with JPY 100m or less stated capital are entitled to 100% deduction of NOL The 100% deduction of NOL for qualified SMEs is not available if the corporation is a directly or indirectly wholly owned subsidiary of large corporation (either Japanese or non-japanese) whose paid-in capital is the equivalent of JPY 500m or more at the end of fiscal year or if the whose shares are listed. Page 15

16 Financing - Overview Germany GER GmbH Japan has three types of interest deduction limitation rules: I/C loan 100% Commission for guarantee Guarantee for loan Thin capitalization rules Earning stripping rules Japan JP Co bank loan Bank Limitation of DRD for the amount of the interests allocated to acquisition costs of the shares (only applicable to less than 100% shareholding) No withholding tax on interest Tax consolidation Page 16

17 VI. Japan tax reform 2017 Page 17

18 Japan tax reform 2017 Enacted March 28, 2017 Give top priority to economic revitalization and overcoming deflation Tax reform to enhance Japan s growth potential, innovation and working-style Revisions to corporate income tax to strengthen competitiveness, corporate governance and productivity Revision of R&D tax incentives Revision of director compensation Establishment of taxation rules for spin-offs Revision of reorganization taxation rules Responding to the internationalization of the economy and preventing tax abuse Revision of CFC (Controlled Foreign Entity) income inclusion rules Revision of inheritance tax on foreign property Page 18

19 R&D tax credit range will expand General R&D credit NEW Current Two-year period After two-year period Large company 8-10 % of R&D 6-14 % 6-10% SME 12% 12% - 17% 12% Credit ratio 14% 10% 9% 6% Credit ratio for large companies 6% (lower limit) 8.5% 9% 14% (upper limit) Credit ratio Incremental R&D ratio +5% -25% ~ +5% Incremental R&D ratio Credit ratio 9%+[Incremental R&D ratio - 5%] 30% 9%-[5% - Incremental R&D ratio] 10% -25% 6% 0% -35% 25% -25% -15% -5% 0% + 5% 15% % 35% Incremental R&D ratio = R&D - average R&D during the past 3 years Average R&D during the past 3 years Incremental R&D ratio Page 19

20 Service R&D and additional R&D credit Scope of qualified R&D will expand Current: Product development or improvement, origination or invention of technology NEW: Development costs for IoT ( Internet of Things ), Big Data, AI (i.e. service R&D or R&D for industry 4.0) Examples of service R&D include: Health care services collection and analysis of personal health information (e.g. exercise, sleeping conditions or heartbeat) to provide tailored fitness or dietary plan Anticipation of natural disaster services collection and analysis of geography and weather conditions by drones to anticipate natural disasters Agricultural services collection and analysis of temperature or humidity at farms by sensors to distribute useful information for cultivation Changes to additional R&D credit The high standard-type R&D credit will be extended (additional two years) As an alternative to the high standard-type R&D credit, companies can increase the credit limit of the general R&D credit by 10% (to 35%) The step-up-type R&D credit will be repealed Page 20

21 Tax credit for increase in salaries Large companies The tax credit conditions for large companies will be tightened Requirements Current NEW (large companies) Gross salary Average salary 1. Increase by certain percentage compared to the base period (i.e. fiscal years starting on or after 1 April 2012) (at least 5% for FY18) 1. Same 2. More than previous year 2. Same 3. More than previous year 3. At least 2% or more than previous year A bonus tax credit (2%) will be added to the 10% tax credit if the average salary increases at least by 2% compared to the previous year Current NEW Gross salary Gross salary >2% 12% 2% 2% 3% 4% 5% 10% tax credit 2% 2% 3% 4% 5% 10% tax credit FY13 14 Base period FY13 14 Base period Page 21

22 Reorganization: Spin-off Spin-off will be tax qualified Current: A spin-off transaction, under which a business or a subsidiary is separated and distributed to non-controlling shareholders, is subject to tax (the distributing company is subject to tax on gains and non-controlling shareholders recognize deemed dividends) NEW: A tax qualified spin-off transaction (an incorporation-type separation demerger or a distribution in-kind) will be a tax-deferral transaction Incorporation-type separation demerger Distribution in-kind of subsidiary Public Public No deemed dividend Public Public No deemed dividend A co No shareholders control A co B business A co Only B co shares are provided in proportion to the ownership Incorporation -type separation demerger B co (B business) A co No shareholders control A co 100% A co Distribution of B co shares in proportion to the ownership No tax on gain B co No tax on gain B co Page 22

23 Reorganization: other updates Assets subject to mark-to-market under a non-tax qualified share-for-share exchange and tax consolidation will be limited Mark-to-market will no longer be required for assets, of which the book value is less than JPY10 million, under a non-tax qualified share-for-share exchange and tax consolidation after 1 October 2017 Internally generated goodwill will no longer be subject to mark-to-market Amortization of goodwill Goodwill will be amortized on a monthly basis (full-year amortization in the first year will no longer be available) Other changes on tax qualified reorganization requirements Ownership continuation requirement under a separation demerger within a group Shareholder continuation requirement under joint business-type reorganizations Current It is expected both the transferor company and the transferee company will continue to be controlled by the common shareholder If the number of the shareholders of the target is less than 50, there has been an expectation that at least 80% of the shareholders of the target hold the newly issued shares continuously NEW It is expected that the transferee company will be controlled by the common shareholder (it will no longer be necessary for the transferor company to be controlled) There has been an expectation that the parent of the target (more than 50% ownership) hold the newly issued shares continuously Page 23

24 VII. Transfer pricing and BEPS Page 24

25 Transfer Pricing Reporting Requirements Base Erosion and Profit Shift ( BEPS ) OECD Initiative Action 13 Transparency readiness Master file High level information about the MNC s business, transfer pricing policies and agreements with tax authorities in a single document available to all tax authorities where the MNC has operations. Country-by-Country Report High level information about multinational corporation s ( MNC ) jurisdictional allocation of revenue, profits, taxes, assets and employees to be shared with all tax authorities where the MNC has operations. Local file Detailed information about the MNC s local business, including related party payments and receipts for products, services, royalties, interest, etc. + Notifications Page 25

26 Overview of Master File 1. Master File period covered and submission date First year of Master File will be the year commencing on or after 1 April 2016, to be submitted within 1 year of the year end 2. MNCs exempted from submitting the Master File Local entities of groups with global consolidated sales of less than 100 billion yen in the most recent financial year will be exempt 3. Language English or Japanese June January December December 2018 Period for CbC Report FYE 31 December 2017 Master File needed if sales for FYE 31 December 2017 were greater than 100bn yen Deadline for Master File Page 26

27 Overview of Local File 1. Local File first period covered First year of Local File will be the year commencing on or after 1 April Deadline for preparation and submission Contemporaneously requirement for preparation (prior to tax return, which is 2 or 3 months following year end depending on whether an extension is in place) Once requested taxpayer has a maximum off 45 days to submit. Following this, the examiner has the right to employ presumptive taxation or secret comparables 3. Exemptions from preparing the Local File Not required if total of transactions with a foreign related party (applied per foreign entity) does not exceed JPY 5 billion (or JPY 300m for intangible transactions) for preceding fiscal year (or current year if no preceding year. 60 days to submit upon request if exempt from Local File requirement 4. Language No language constraint, though may need to be translated upon request of examiner June January December Period for Local File 2018 FYE 31 December Feb/March 2019 Local File needed if transactions with a related party are JPY 5 bn or JPY 300m for intangible assets Deadline for Local File Page 27

28 Overview of CbC Report Country by Country Report ( CBC Report ) 1. When is the first relevant period and what is the submission date? First year of CbC Report will be the year commencing on or after 1 April 2016, to be submitted within 1 year of the year end 2. Who creates the CbC Report and when is it submitted in Japan? Parent company will create and submit the CbC Report to the tax authority it is resident in Subsidiaries (and PEs) of overseas headquartered companies not submitting in a country with a double tax convention with Japan will need to submit a CbC Report 3. MNCs exempted from submitting the CbC Report Companies with global consolidated sales of less than JPY 100 billion in the most recent financial year will be exempt 4. Language English June January December December 2018 Period for CbC Report FYE 31 December 2017 CbC Report needed if sales for FYE 31 December 2017 were greater than 100bn yen Deadline for CbC Report Page 28

29 VIII. Indirect taxes Page 29

30 General principles Consumption tax applies to taxable transactions : The supply of goods or services in Japan by a taxable person The importation of goods into Japan The provision of crossborder electronic services by foreign entities, such as advertising on the internet, cloud services, consulting via telephone/ , and selling e-books, music, software licences etc. Consumption tax is charged for taxable transactions at a flat rate of 8%. Reduced rates do currently not apply. According to current legislation, the general tax rate will increase to 10% effective 1 October 2019 (certain products will be exempted from the rate increase, such as food and non-alcoholic beverages, where the tax rate stays at 8%) A taxable person is any business entity or individual that provides taxable supplies of goods or services in the course of doing business in Japan, and exceeds sales of JPY 10m during the base period (for start-up businesses without a base year and less than JPY 10m in share capital, it is a tax-exempt enterprise for two years, unless it elects and applies to become a taxable enterprise from the beginning) Page 30

31 Input tax credit A taxable person may recover input tax (consumption tax charged on goods and services supplied to it for business purposes). Input tax is generally recovered by deducting it from output tax (consumption tax charged on products/services sold). lf a taxpayer intends to take a tax credit in the consumption tax return resulting in the refund of such consumption tax paid to recipient, the taxpayer must keep accounting records including the following items: Name of the vendor Description of the goods sold or of the services provided Date of the sale or of the service provided Gross amount of the consideration (including consumption tax) In addition, purchase invoices as well as the accounting books, should be kept for 7 years. Page 31

32 Import consumption tax and customs duty Goods imported into Japan are subject to Consumption tax (see above) Customs duty (tariffs), and Excise taxes ( other internal taxes ) for products such as liquor, tobacco, petroleum etc. Japan is a member of the WTO and applies the harmonized system (HS) of code numbers for identifying products subject to customs duty Customs duty rates are generally MFN (Most Favored Nation) duty rates for imports from WTO member states with MFN status. Preferential duty rates are available under Free Trade Agreements or Economic Partnership Agreements. Special rates would be granted to certain developing countries. The tax base is the price or the quantity of goods. An ad valorem rate (i.e. a percentage) is applied to the value of imported goods and a specific rate rate is imposed without regard to the value of the imported goods. The taxable value is the sum of the wholesale price, freight and insurance (CIF price). This value is also applied to calculate import consumption tax. If no such values are available more complex, alternative valuation methods are applied. Page 32

33 Royalties, transfer pricing, tariff quotas Special consideration is required to determine the taxable value including the following cases: Royalties and license fees are paid by the buyer (directly or indirectly) as a condition of the import transaction of the imported goods Year-end adjustments from Transfer Pricing arrangements are applied Japan customs duty is mostly tariff free, but rates remain high for a few sensitive items Agricultural products Leather and leather shoes Chemicals Raw materials (plastic, metal etc.) Japan applies a system of tariff quotas, where import tariffs on imports of specific goods are low up to a certain quantity, but higher tariffs are imposed for quantities exceeding the specified volume (e.g. for rice, dairy products, footwear) Other regulations to be considered for importing goods into Japan: Import restrictions, Import license requirements, Labelling and marking requirements etc. Page 33

34 IX. Overview of individual income and inheritance tax Page 34

35 Japanese effective average income tax and social security rates (55.9% incremental rate) Income Income Tax Social Security Total 3 mil JPY 4% 15.7% 20% 6 mil JPY 8% 15.1% 23% 12 mil JPY 16% 11.6% 28% 24 mil JPY 28% 6.5% 35% 48 mil JPY 40% 3.1% 43% Page 35

36 Business traveller and expatriate taxation Non-permanent resident: Foreigner entering Japan with the intention to stay for at least one year. Center of living counts in case of doubt (AU-J tax treaty, Article 4). Subject to Japanese income tax with dividends and interest remitted into Japan. Employment income is subject to income tax on a world-wide basis, unless the expat is on an overseas payroll and an employee (i.e. no director). In the latter case the expat is taxable with Japanese working days only. Non-resident: Foreigner staying up to one year. Subject to 20.42% Japanese income tax with salaries paid by or charged to a Japanese entity, or when staying in Japan for over 183 days. Permanent Japanese resident: Expats staying in Japan for a total of 5 years or more during the last 10 years are subject to worldwide income taxation. Subject to asset reporting obligations with shares exceeding 100 mil JPY and overseas assets exceeding 50 mil JPY. Non-permanent residents must report assets only when their gross assets exceed 300 mil JPY. Page 36

37 Capital gains taxation of non-permanent residents Non-permanent residents are foreigners who have the intention to stay or have stayed in Japan for one year; and have spent in aggregate less than 5 years in Japan over the past 10 years Capital gains on securities incurred until 31/12/2016 were subject to income tax at 20.42% only if the gain was remitted into Japan During 1/1/ /3/2017 any securities capital gains will be taxed Exemption of taxation of capital gains from 1 April 2017 for securities IF acquired before 1 April 2017 AND IF traded on a foreign securities exchange Page 37

38 Japanese individual income tax planning Effective income tax (50.8%) Director's Housing 17.8% 25.4% Employee Housing 3.8% Company Car 0.0% 14.5% 100% International School Fee 50.8% 0% (donation) Home Leave 0.0% 40 mil Y retirem. allow. 9.1% 12.7% Completion Bonus 20.4% Basic Allowance overseas working days non-director overseas payroll 2.2 mil Y working days in Japan Page 38

39 Japanese Inheritance Tax liabilities on foreigners Unlimited taxpayer Heir is resident of Japan at time of death, or Decedent is resident in Japan at time of death Heir is subject to inheritance tax on the value of worldwide assets, NEW if having stayed in Japan for 10 years or holding a permanent resident or spouse visa NEW: IF having stayed a shorter period with Type 1 Visa, only Japan assets NEW: Extended unlimited taxpayer After having stayed in Japan for at least 10 years For 5 years after departure from Japan Limited taxpayer Heir is neither resident in Japan at time of death nor Decedent has a residence in Japan at time of death nor Subject to extended unlimited tax liability Heir is subject to inheritance tax on the value of Japanese assets only Page 39

40 Japanese and non-japanese assets Whether assets are Japanese or non-japanese assets is dependent on the location of assets in or outside of Japan at the time of death Assets Deposits (savings) at a bank Securities such as shares, debentures, stock options, etc. Life insurance Receivables Location of assets Where the branch office in which the deposit was made is situated Where the issuer of the securities has its head office Insurance company head office Location of debtor Page 40

41 Introduction 5 years extended Inheritance and Gift Tax liability on foreigners having left Japan Extended 5 years unlimited liability, where non-japanese heirs or donees are domiciled outside Japan, if the decedent or the donor over the past 15 years was domiciled in Japan within the past 10 years (excluding foreigners on temporary stay, i.e. having spent less than 10 years) and has departed from Japan Decedent Donor No residence at the time of death or gift Revised to "having had a residence within the previous 10 years Heir Donee Not Japanese citizen No residence in Japan Pre-revision Domestic asset (taxable) Foreign asset (not taxable) Post-revision Domestic asset (taxable) Foreign asset (taxable) Applicable on assets acquired by inheritance or gift as of 1 April 2017 Page 41

42 Japanese inheritance and gift tax exposure on the sole heir to an estate or donee 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Page 42

43 Japanese inheritance exposure of an expat family (married couple with two children) from the death of a spouse 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% Page 43

44 Spouse and two children inherit a family home Asset Fair market value Taxable inheritance Land (80% reduction) Yen Yen Building (70% of fair market value) Yen Yen Cash Yen Yen 30 mil JPY base allowance Yen 6 mil JPY per heir allowance Yen Yen Yen *prior to spouse exemption 5.05% effective inheritance tax on a the spouse and two children Page 44

45 X. Tax controversy Page 45

46 Tax controversy in inheritance tax matters Inheritance tax filing obligation: 10 months after receiving knowledge or departing from Japan Execution of inheritance tax assessments under recent tax treaties Compliance of extraterritorial application of the Japanese inheritance tax law with the law of nations? Genuine, relevant and sufficient nexus? Public order? German Constitutional Court: The imposition of tax against an overseas foreigner requires that reasonably justified nexus is given, such as citizenship, physical presence, residence, and abode United Kingdom: The territoriality principle in customary international law dictates that one State should not seek to legislate in respect of the conduct of nationals established in another State in the absence of a sufficient nexus for so doing. (cf. EU Financial Transaction Tax) Page 46

47 Sample tax audit process Day - 2 Weeks: Announcement Day 1: First Meeting Day 2~: Field Audit (actual periods may deviate) Assessment Note (or Filing of amended T/R) Day x: Presentation of Issues 2 months: Request for reinvestigation x+7: Response by Taxpayer supplementary info and explanations +1mo.: Reinvestigation Decision on reinvestigation Request for reconsideration x+14: Discussion and negotiations on issues Administrative review by Tax Tribunal Day y : Internal approval procedures and review, in case the matter is of high profile or complex Decision on reconsideration Appeal District Court y+28: Internal Final Meeting +30: Presentation of conclusion Page 47

48 Tax audit process Preparatory Stage Company Perspective Questionnaire Internal pre-meeting, discussions with key employees Information process management Compilation and preparation of documents 2 weeks response time Optional rehearsals Page 48

49 Tax audit process Post-audit procedures Completion of the audit - three potential outcomes Little correction required Compromise reached Amended return filed Request for assessment note No compromise reached Assessment note Tax tribunal, tax litigation Page 49

50 Speakers and contacts Hans-Peter Musahl Partner International and Transaction Tax Services Tel: hans-peter.musahl@jp.ey.com Heads the Ernst & Young German Tax Desk 20 years professional services experience, thereof 16 in Japan Chairman of the EBC Tax Committee Lecturer at Keio University Law School German Attorney at Law German Tax Accountant Advice on tax efficient group reorganizations Support and liasing in cross border tax audits Structuring of acquisitions of publicly listed and medium sized privately held Japanese companies Structuring of supply chain management improvements Greenfield inbound investment advice Japan inbound real estate investments Page 50

51 Speakers and contacts Juergen Dumont Manager Global Compliance & Reporting Mobile: Juergen joined EY in February 2017 and is based in the Tokyo office Juergen has 13 years of professional services experience. He worked for another Big Four accounting firm in Duesseldorf and Tokyo as German tax advisor and certified public accountant. At Duesseldorf, Juergen served Japanese trading and manufacturing companies as well as Japanese financial institutions. In Tokyo he has served European inbound clients with a wide range of industries, including automotive, consumer goods, chemical, financial services and software Prior to joining EY, Juergen gained extensive experience as finance executive. In Germany he worked as SVP Finance & Controlling at a software company and as CFO at a publicly traded manufacturer of access control and security solutions. In Japan he worked as Head of Controlling at an automotive supplier. Juergen serves inbound businesses in compliance and reporting matters, including tax, accounting and payroll services. Page 51

52 EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization and/or one or more of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. About EY s Tax services EY s tax professionals in Japan provide you with deep technical knowledge, both global and local, combined with practical, commercial and industry experience. Our highly regarded tax professionals operate in four major cities in Japan. Our talented people, consistent methodologies and unwavering commitment to quality service help you to build the strong compliance and reporting foundations and sustainable tax strategies that help your business succeed Ernst & Young Tax Co. All Rights Reserved. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice.

53 Österreichisches AußenwirtschaftsCenter Tokio Motoazabu , Minato-ku Tokyo , Japan