Market Taxation Guide - Japan

16.05.2023

This Market Taxation Guide (Japan) provides the following details:

  • Reference information about all taxes applied at source to securities deposited in Clearstream Banking1; and
  • Instructions for obtaining relief at source or a refund of withholding tax, where these are available, through Clearstream Banking.

New and improved tax information and procedures that become available will be included on an ongoing basis.

Important note:

This Market Taxation Guide (including any attachments and other links) is for informational purposes only and is not intended and should not be considered to be legal advice on any subject matter. Readers of this Market Taxation Guide, whether customers or otherwise, should not act or refrain from acting on the basis of any information included in this Market Taxation Guide without seeking appropriate legal or other professional advice.

Withholding tax

Holding restrictionWithholding
tax rate
Relief
at source
Quick
refund
Standard
refund
Japanese Government Bonds (JGBs)
Yesa

0%

No withholding tax on interest paid in Clearstream Banking as only tax-exempt beneficial owners are eligible in Clearstream Banking.

N/A

N/A

N/A

Japanese corporate bonds and Japanese municipal bonds
Yesa

0%

No withholding tax on interest paid in Clearstream Banking as only tax-exempt beneficial owners are eligible in Clearstream Banking.

N/A

N/A

N/A

Samurai bonds

No

20.315%

Non-Residents of Japan

Yes

N/A

No

Residents of Japan (Corporations)

Yes

N/A

No

Designated Financial Institutions (DFIs) resident in Japan

Yes

N/A

No

Japanese Convertible Bonds (JCBs)

No

15.315%

Residents of Double Taxation Treaty (DTT) countries

Yes

N/A

Yes

Japanese Eurobonds following the ICMSA procedure

No

15.315%

Non-Residents of Japan

Yes

N/A

No

Designated Financial Institutions (DFIs) resident in Japan

Yes

N/A

No

Tax residents of Japan paid via Payment Handling Agent (PHA) in Japan

Yes

N/A

No

Japanese Eurobonds not following the ICMSA procedure

No

15.315%

Non-Residents of Japan

Yes

N/A

No

Designated Financial Institutions (DFIs) resident in Japan

Yes

N/A

No

Japanese listed equities, ETFs and REITs

No

15.315%

Residents of Double Taxation Treaty (DTT) countries

Yes

N/A

Yes

Tax-exempt beneficial owners

Yes

N/A

Yes

Japanese unlisted equities, ETFs and REITs

No

20.42%

N/A

N/A

N/A

Japanese American Depository Receipts (ADRs)

No

15.315%

Residents of Double Taxation Treaty (DTT) countries

Yes

N/A

No

Tax-exempt beneficial owners

Yes

N/A

No

a. Only exempt beneficial owners (non-residents of Japan and Designated Financial Institutions (DFIs) resident in Japan) may hold Japanese government, corporate or municipal bonds via Clearstream Banking.

Capital gains tax

There is no capital gains tax withheld through Clearstream Banking on securities held in Clearstream Banking. Capital gains tax may however be payable on specific gains. Clearstream Banking does not assist in this regard. Please consult your tax advisor for further information.

Stamp Duty

There is no stamp duty withheld through Clearstream Banking on securities held in Clearstream Banking. Stamp duty may however be payable on specific transactions. Clearstream Banking does not assist in this regard. Please consult your tax advisor for further information.

Notes on tax reclaims

Customers warrant the completeness and accuracy of the information they supply to Clearstream Banking.

It is the customer's responsibility to determine any entitlement to a refund of tax withheld, to complete the forms required correctly and to calculate the amount due. Clearstream Banking is under no obligation to carry out any investigation in respect of such information.

With respect to tax reclaims in general, customers are reminded that Clearstream Banking accepts no responsibility for their acceptance or non-acceptance by the tax authorities of the respective country.

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1. “Clearstream Banking” refers collectively to Clearstream Banking S.A. and Clearstream Banking AG (for Clearstream Banking AG customers using Creation accounts).