Market Taxation Guide - Japan

09.02.2017

This Market Taxation Guide (Japan) provides the following details:

  • Reference information about all taxes applied at source, through Clearstream Banking and its local depositories, to securities deposited in Clearstream Banking; and
  • Instructions for obtaining relief at source or a refund of withholding tax, where these are available, through Clearstream Banking.

New and improved tax information and procedures that become available will be included on an ongoing basis.

Important note:

This Market Taxation Guide (including any attachments and other links) is for informational purposes only and is not intended and should not be considered to be legal advice on any subject matter. Readers of this Market Taxation Guide, whether customers or otherwise, should not act or refrain from acting on the basis of any information included in this Market Taxation Guide without seeking appropriate legal or other professional advice.

Withholding tax

Holding restrictionWithholding
tax rate
Relief
at source
Quick
refund
Standard
refund
Japanese Government Bonds (JGBs)
Yes a0%
No withholding tax on interest paid in Clearstream Banking as only tax-exempt beneficial owners are eligible in Clearstream Banking.N/AN/AN/A
Japanese corporate bonds and Japanese municipal bonds
Yes a0%
No withholding tax on interest paid in Clearstream Banking as only tax-exempt beneficial owners are eligible in Clearstream Banking.N/AN/AN/A
Samurai bonds
No20.315%
Non-Residents of JapanYesN/ANo
Residents of Japan (Corporations)YesN/ANo
Designated Financial Institutions (DFIs) resident in JapanYesN/ANo
Japanese Convertible Bonds (JCBs)
No15.315%
Residents of Double Taxation Treaty (DTT) countriesYesN/AYes
Japanese Eurobonds following the ICMSA procedure
No15.315%
Non-Residents of JapanYesN/ANo
Designated Financial Institutions (DFIs) resident in JapanYesN/ANo
Tax residents of Japan paid via Payment Handling Agent (PHA) in JapanYesN/ANo
Japanese Eurobonds not following the ICMSA procedure
No15.315%
Non-Residents of JapanYesN/ANo
Designated Financial Institutions (DFIs) resident in JapanYesN/ANo
Japanese listed equities, ETFs and REITs
No15.315%
Residents of Double Taxation Treaty (DTT) countriesYesN/AYes
Tax-exempt beneficial ownersYesN/AYes
Japanese unlisted equities, ETFs and REITs
No20.42%
Residents of Double Taxation Treaty (DTT) countriesbN/ANo
Tax-exempt beneficial ownersbN/ANo
Japanese American Depository Receipts (ADRs)
No15.315%
Residents of Double Taxation Treaty (DTT) countriesYesN/ANo
Tax-exempt beneficial ownersYesN/ANo

a. Only exempt beneficial owners (non-residents of Japan and Designated Financial Institutions (DFIs) resident in Japan) may hold Japanese government, corporate or municipal bonds via Clearstream Banking.
b. There is no market practice applicable for unlisted equities in Japan and, as such, any relief will be offered on a case-by-case/"best efforts" basis.

Capital gains tax

There is no capital gains tax withheld through Clearstream Banking on securities held in Clearstream Banking. Capital gains tax may however be payable on specific gains. Clearstream Banking does not assist in this regard. Please consult your tax advisor for further information.

Stamp Duty

There is no stamp duty withheld through Clearstream Banking on securities held in Clearstream Banking. Stamp duty may however be payable on specific transactions. Clearstream Banking does not assist in this regard. Please consult your tax advisor for further information.

Notes on tax reclaims

Customers warrant the completeness and accuracy of the information they supply to Clearstream Banking.

It is the customer's responsibility to determine any entitlement to a refund of tax withheld, to complete the forms required correctly and to calculate the amount due. Clearstream Banking is under no obligation to carry out any investigation in respect of such information.

With respect to tax reclaims in general, customers are reminded that Clearstream Banking accepts no responsibility for their acceptance or non-acceptance by the tax authorities of the respective country.