Japan: Eurobonds following ICMSA procedure or tax election - update to documentation for relief at source


Clearstream Banking1 inform customers that effective


in order to obtain exemption at source of withholding tax on income from Japanese Eurobonds, following the ICMSA procedure or Japanese tax election, a per-payment instruction is no longer required.

Impact on customers

Customers who submit any of the following documentation:

  • The Master Representation for Debt Obligations issued outside Japan before 1 April 2010 or on/after 1 April 2010; or
  • The Excluded Securities Notice; or
  • The Japanese Payment Handling Agent (PHA) certificate

do not need to provide Clearstream Banking with a per-payment Corporate Action Instruction via Xact Web Portal, CreationOnline or SWIFT MT565 as they will no longer be accepted by Clearstream Banking.

Further information

The Market Taxation Guide - Japan will be updated in due course.

For further information, customers may contact the Clearstream Banking Tax Help Desk or Clearstream Banking Client Services or their Relationship Officer.


1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.