Beneficial owners recognised in Japan

Residents of Double Taxation Treaty (DTT) countries

Relief and reclaim procedures are in place for residents of DTT countries with regard to withholding tax on income from the following security types, as indicated:

• Japanese Convertible Bonds (JCBs):
  
  The standard rate of withholding tax on interest from JCBs is 15.315% in Clearstream.
  Relief at source is available to beneficial owners that qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and Japan.
  By submitting the appropriate documentation, clients can apply through Clearstream for a standard refund on behalf of beneficial owners for whom relief at source has not been obtained.
• Listed equities, ETFs and REITs:
  
  The standard rate of withholding tax on dividends from Japanese listed equities, ETFs and REITs is 15.315% in Clearstream.
  Relief at source is available to beneficial owners that qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and Japan.
  By submitting the appropriate documentation, clients can apply through Clearstream for a standard refund on behalf of beneficial owners for whom relief at source has not been obtained.
• Japanese American Depository Receipts (ADRs):
  
  The standard rate of withholding tax on dividends from Japanese ADRs is 15.315% in Clearstream.
  Relief at source is available to beneficial owners that qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and Japan.
  Standard refund on behalf of beneficial owners for whom exemption has not been obtained is not available via Clearstream.

Tax-exempt beneficial owners

Relief and reclaim procedures are in place for tax-exempt beneficial owners with regard to withholding tax on income from the following security types, as indicated:

• Listed equities, ETFs and REITs:
  
  The standard rate of withholding tax on dividends from Japanese listed equities, ETFs and REITs is 15.315% in Clearstream.
  Exemption at source is available to beneficial owners that duly qualify.
  By submitting the appropriate documentation, clients can apply through Clearstream for a standard refund on behalf of beneficial owners for whom exemption at source has not been obtained.
• Japanese American Depository Receipts (ADRs):
  
  The standard rate of withholding tax on dividends from Japanese ADRs is 15.315% in Clearstream.
  Exemption at source is available to beneficial owners that duly qualify.
  Standard refund on behalf of beneficial owners for whom exemption has not been obtained is not available via Clearstream.

Non-residents of Japan

Relief at source is available for non-residents of Japan with regard to withholding tax on income from the following security types, as indicated:

• Japanese government, corporate and municipal bonds:
  
  The standard rate of withholding tax on interest from Japanese Government Bonds (JGBs), Japanese corporate bonds and municipal bonds is 0% in Clearstream, as only tax-exempt beneficial owners are eligible to hold these bonds via Clearstream.
  Non-residents qualify as tax-exempt beneficial owners provided that the appropriate documentation has been submitted to Clearstream before investment.
• Japanese Eurobonds:
  
  The standard rate of withholding tax on interest from Japanese Eurobonds is 15.315% in Clearstream.
  Exemption at source is available to non-residents beneficial owners.
  Standard refund on behalf of non-residents beneficial owners for whom exemption has not been obtained is not available via Clearstream.
• Samurai bonds:
  
  The standard rate of withholding tax on interest from Samurai bonds is 20.315% in Clearstream.
  Exemption at source is available to non-resident beneficial owners.
  Standard refund on behalf of non-resident beneficial owners for whom exemption has not been obtained is not available via Clearstream.

Designated Financial Institutions (DFIs) resident in Japan

Relief at source is available for DFIs in Japan with regard to withholding tax on income from the following security types, as indicated:

• Japanese government, corporate and municipal bonds:
  
  The standard rate of withholding tax on interest from Japanese Government Bonds (JGBs), Japanese corporate bonds and municipal bonds is 0% in Clearstream, as only tax-exempt beneficial owners are eligible to hold these bonds via Clearstream.
  DFIs qualify as tax-exempt beneficial owners provided that the appropriate documentation has been submitted to Clearstream before investment and provided that the DFI is a Clearstream client holding proprietary JGBs and/or Japanese corporate or municipal bonds only.
• Samurai bonds:
  
  The standard rate of withholding tax on interest from Samurai bonds is 20.315% in Clearstream.
  Exemption at source is available to DFIs provided that the DFI is a Clearstream client holding proprietary Samurai bonds only.
  Standard refund on behalf of DFIs for whom exemption has not been obtained is not available via Clearstream.
• Japanese Eurobonds:
  
  The standard rate of withholding tax on interest from Japanese Eurobonds is 15.315% in Clearstream.
  Exemption at source is available to DFIs provided that the DFI is a Clearstream client holding proprietary assets only.
  Standard refund on behalf of beneficial owners for whom exemption has not been obtained is not available via Clearstream.

Tax residents of Japan (individual or corporation) who receive interest payments through a Payment Handling Agent (PHA) in Japan

Relief at source is available for tax residents paid through a PHA in Japan with regard to withholding tax on income from Japanese Eurobonds, as indicated:

• Japanese Eurobonds:
  
  The standard rate of withholding tax on interest from Japanese Eurobonds is 15.315% in Clearstream.
  Exemption at source is available to tax residents paid through a PHA in Japan.
  Standard refund on behalf of tax residents paid through a PHA in Japan and for whom exemption at source has not been obtained is not available via Clearstream.

Tax residents of Japan (corporation)

Relief at source is available for Corporations tax residents of Japan with regard to withholding tax on income from Samurai bonds, as indicated:

• Samurai bonds:
  
  The standard rate of withholding tax on interest from Samurai bonds is 20.315% in Clearstream.
  Relief at source is available for Japanese corporations (domestic corporation) residents in Japan for Japanese tax purposes.
  A Japanese corporation is designated in Act No. 34 of 31 March 1965, Part I Chapter I Article 2-3 of the Corporate Tax Act as a corporation that has its head office or principal office in Japan and is eligible for a reduced rate of Japanese withholding tax (that is, 15.315% for Samurai bonds).
  Standard refund on behalf of beneficial owners for whom relief at source has not been obtained is not available via Clearstream.