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


Note: This announcement, originally published on 4 July 2022, has been updated to provide further information for customers on the restoration of the per-payment instruction as part of the documentation for relief at source. Changes have been highlighted.

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 should be provided when applicable.

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

must, in addition, provide Clearstream Banking with a per-payment instruction via SWIFT, CreationOnline or Xact Web Portal.

Note: The per-payment instruction must include:

  • Account number;
  • ISIN;
  • Corp ID;
  • A breakdown of the position with the quantity (customers should refer to the eligible balance on the account) and the respective tax rate to apply;
  • the customer’s full contact details.

The per-payment instruction should be submitted via SWIFT, CreationOnline or Xact Web Portal. Customers are required to specify in field INST (SWIFT) or in the Corporate actions narrative (CreationOnline) the following wording, as applicable:

  • "submission of Master Representation"; or
  • "submission of Excluded Securities Notice"; or
  • "submission of Japanese Payment Handling Agent Certificate".

Customers who have already provided the required documentation to Clearstream Banking are not required to provide any per-payment instruction if the current certificate is still valid.

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.