For fiscal years beginning on or after April 1, 2024, Japan has introduced the Income Inclusion Rule (“IIR”) under the Global Minimum Tax rules, in the form of Corporate Income Tax on the International Minimum Tax Amount. This article explains, from a Japanese tax perspective, the actions that Japanese subsidiaries with non-Japanese parent companies should take to comply with the Global Minimum Tax rules for the fiscal year ending (“FYE”) December 2025.
Please note that this article assumes that the Japanese subsidiaries do not directly or indirectly own any non-Japanese subsidiaries.

1.Fiscal Years Subject to the Japanese IIR
The Japanese IIR applies to fiscal years beginning on or after April 1, 2024. Accordingly, for companies with a December fiscal year-end, it first applies to FYE December 2025.

2.Companies Subject to the Japanese IIR
The Global Minimum Tax rules, including the IIR apply to Multinational Enterprise (“MNE”) Groups whose annual consolidated revenue is EUR 750 million or more in at least two of the four fiscal years immediately preceding the fiscal year for which the Global Minimum Tax rules apply.
Accordingly, to determine whether an MNE Group is subject to the Global Minimum Tax rules for FYE December 2025, its annual consolidated revenue for FYE December 2024, 2023, 2022 and 2021 must be reviewed.
If the annual consolidated revenue was EUR 750 million or more in at least two of these four fiscal years, the MNE Group is subject to the Global Minimum Tax rules for FYE December 2025.
On the other hand, if the annual consolidated revenue was EUR 750 million or more in only one or none of these four fiscal years, the MNE Group is not subject to the Global Minimum Tax rules for FYE December 2025, and the filings described in Section 3 below are not required.

3.Documents to Be Filed with the Japanese Tax Authority
The documents to be filed by Japanese subsidiaries differ depending on the implementation status of Global Minimum Tax in the jurisdiction of the Ultimate Parent Entity (“UPE”) and other factors. The filing requirements are explained below in three scenarios.
Please note that the following assumes that, where the IIR has been implemented in the jurisdiction of the UPE, the UPE duly files the GloBE Information Return (“GIR”) with the tax authority in its jurisdiction.

1. The IIR has been implemented in the jurisdiction of the UPE, and the GIR MCAA (Multilateral Competent Authority Agreement on the Exchange of GloBE Information) is in effect between that jurisdiction and Japan.
   This applies, for example, where the UPE is located in the United Kingdom or South Korea.
   Japanese subsidiaries are required to file a Notification for Ultimate Parent Entity of an MNE Group (“GIR Notification”) with the Japanese Tax Authority. Please note that the GIR Notification is different from the Notification for Ultimate Parent Entity required under Japanese Transfer Pricing documentation rules.The Japanese subsidiary is not required to file the GIR.
2. The IIR has been implemented in the UPE jurisdiction, but the GIR MCAA is not in effect between that jurisdiction and Japan
   This applies, for example, where the UPE is located in Germany or France.
   In principle, Japanese subsidiaries are required to file the GIR with the Japanese Tax Authority.
3. The IIR has not been implemented in the UPE jurisdiction
   This applies, for example, where the UPE is located in the United States or China.
   In principle, Japanese subsidiaries are required to file the GIR with the Japanese Tax Authority.

4.Filing Deadline for Documents to Be Filed with the Japanese Tax Authorities
The filing deadline is within one year and six months from the day following the end of the Fiscal Year subject to the Japanese IIR. Accordingly, for FYE December 2025, the filing deadline is the end of June 2027.

For subsequent Fiscal Years, the filing deadline is within one year and three months from the day following the end of the Fiscal Year.

This article is based on information available as of July 31, 2026. The tax treatment applicable to Japanese subsidiaries with non-Japanese parent companies may change in the future due to amendments to Japanese tax laws, developments in the implementation of Global Minimum Tax in other jurisdictions, or other factors.
This article is intended to provide a general overview of Global Minimum Tax in Japan. After obtaining a general understanding of Global Minimum Tax in Japan through this article, the specific tax treatment applicable to each Japanese subsidiary should be confirmed separately for each Fiscal Year.