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日本于1988年进行税制改革时,将对避税港的有关制度作为新规定引入到《税收特别措施法中》,并在1992年进行税制改革时,又对该法规进行了修改,其内容简而言之为:当外国子公司所得的税收负担存25％以下时,将其保留所得合并到其母公司的国内法人所得中一并计算征税。即“避税港对策税制”。按照避税港对策税制的规定,适用范围为日本国内法人的国外子公司,作为母公司的国内法人。本税制对股东个人(居民)也适用合并计税规定,但因其合并计算方式和法人的计算方式基本相同,故在这里只就作为外国子公司的股东—国内法人进行说明。
When Japan carried out the tax reform in 1988, it introduced the relevant system of tax havens as a new tax law into the “special measures for tax measures.” When the tax reform was carried out in 1992, Japan also amended the relevant regulations. The implication is that when the tax burden on foreign affiliates is kept below 25%, the income from the retained earnings of the foreign affiliates will be included in the income of the domestic legal entity of the parent company, and the tax will be calculated accordingly. That is, “tax shelter response tax system.” In accordance with the provisions of the Tax Have Port Countermeasure Tax System, the scope of application is an overseas subsidiary of a Japanese domestic legal person and a domestic legal person as a parent company. This tax system also applies the tax consolidation provisions to individual shareholders (residents) of a shareholder. However, the method of consolidation is basically the same as that of a legal person. Therefore, only the domestic subsidiary, a shareholder of a foreign subsidiary, is described here.