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- Instruction manual for Tax Exemption
Instruction manual for Tax Exemption
- Instructions for nonresidents and foreign corporations
- Instructions for QFI and QAMI
- Instructions in detail
- Documents needed for each event and method of submission
EventWhatWhenTo whomRemarksOn first purchase Application Form for Withholding Tax Exemption (PDF) → see Form Completion Guide
Documents to verify applicant’s identityWhen the applicant first intends to be exempt from taxation
Qualified foreign intermediary or specified book-entry transfer institution, etc.Not necessary when submitting special case documents
Documents to verify applicant’s identity must be presentedWhen changing name or address Application Form for Amendment (PDF) → see Form Completion Guide
Documents to verify applicant’s identityAt least one day preceding the date of the first interest payment after the change has been effected When receiving interest payments Statement of the Holding Period (PDF) → see Form Completion Guide At least one day preceding the interest payment date Need not normally be prepared when a tax-exempt category account has been established When making additional purchases No procedures requiredWhen transferring No procedures required - Flow of documents
- List of Procedures Necessary to Acquire the Status of a Qualified Foreign Intermediary or Qualified Account Management Institution
- Documents needed for each event and method of submission
EventWhatTo whomRemarksWhen acquiring the status of a qualified foreign intermediary Application Form for Qualified Foreign Intermediary (PDF)
Attached documents
→ see Form Completion GuideSpecified book-entry transfer institutions, etc. Concerning qualified foreign intermediaries When acquiring the status of a qualified account management institution Application Form for Qualified Account Management Institution (PDF)
Attached documents
→ see Form Completion GuideThe Japan Securities Depository Center, Inc. Concerning qualified account management institutions *1 Before applying for QFI, it is necessary to acquire the status of foreign indirect account management institution (FIAMI) in the book-entry transfer system managed by Japan Securities Depository Center Inc. .*2 For procedures necessary to acquire the status of a foreign indirect account management institution (FIAMI), please consult the Japan Securities Depository Center, Inc. - Flow of documents
Detailed Information on Tax Exemption Procedures
1.Requirements for tax exemption, etc.
Types of securities | Book-entry transfer Japan Local Government Bonds |
Item subject to tax exemption | The interest portion of the book-entry transfer JLGBs (Note 1) that corresponds to the holding period (Note 2) |
Eligible investors (Note 3) | Nonresidents individuals and foreign corporations (Note 4) |
Holding method | Holding in transfer account at a specified book-entry transfer institution, etc. (Note 5) or qualified foreign intermediary |
(Note 1)
The difference compared to profit from redemption (i.e. the amount received as a result of redemption (including retirement by purchase) and acquisition cost) is also exempt from tax.
(Note 2)
The amount of the interest portion of the book-entry transfer JLGBs, which corresponds to the period it is held, shall be calculated as below:
・When the first day of the holding period of a book-entry transfer JLGBs by a nonresident individual or a foreign corporation falls on a day prior to the first day of the calculation period for interest accrual on the book-entry transfer JLGBs:
The amount of interest corresponding to the interest calculation period
・When the first day of the holding period of a book-entry transfer JLGBs by a nonresident individual or a foreign corporation falls either on the first day or on a day after the first day of the calculation period for interest accrual on the book-entry transfer JLGBs:
The amount derived by multiplying the amount of interest corresponding to the interest calculation period by the number of days holding the book-entry transfer JLGB, divided by the number of days of the interest calculation period
* Interest calculation period for book-entry transfer JLGBs is 6 months.
* When nonresident individuals or foreign corporations meet the following conditions with respect to book-entry transfer JLGBs (excluding those being recorded/described information relating to book-entry transfer in the tax-exempt category) they have acquired during the interest calculation period, they may add the holding period of the previous holders to their holding period:
(Note 3)
Nonresident individuals or foreign corporations that are trustees of foreign investment trusts are only eligible for tax exemption when said foreign investment trusts are securities investment trusts or publicly offered bond investment trusts, and when they fulfill the requirements (1) or (2) below (i.e. qualified foreign securities investment trusts).
(1)The following conditions:
・That the offering of beneficial securities pertaining to the establishment of the foreign investment trust is conducted by public offer outside Japan, and that this fact is stated in the prospectus of the foreign investment trust or any other document similar thereto.
・That, if the offering of beneficial securities pertaining to the establishment of the foreign investment trust is also conducted inside Japan, the following conditions are met:
(2)That all of the beneficial securities of the foreign investment trust have been acquired as trust assets of other qualified foreign securities investment trusts, and that this fact is stated in the prospectus of the foreign investment trust or any other document similar thereto.
(Note 4)
Interest on book-entry transfer JLGBs paid to nonresident individuals or foreign corporations having permanent establishments in Japan is not eligible for tax exemption if it is attributable to the business conducted by that person in Japan, etc.
(Note 5)
Specified book-entry transfer institutions, etc., are Japanese financial institutions, financial instrument business operators, and other subcustodians that act as account management institutions for JLGBs.
2.Procedures for nonresident individuals and foreign corporations
(1)Documents to submit
To be eligible for tax exemption for interest on book-entry transfer JLGBs, the following documents must be submitted.
Documents
|
Filing timing
|
Remarks
|
Application Form for Withholding Tax Exemption | When the applicant first intends to be exempt from taxation |
・An identification document must be shown upon submission.
・There are cases where the Application Form for Withholding Tax Exemption need not be submitted if a specified book-entry transfer institution, etc., has already submitted special case documents. |
Application Form for Amendment | If there is a change in the name or address of the applicant after submitting the Application Form for Withholding Tax Exemption, at least one day preceding the date of the first interest payment after the change has been effected | |
Statement of the Holding Period | At least one day preceding the interest payment date of the book-entry transfer JLGB | When a specified book-entry transfer institution, etc., or qualified foreign intermediary has submitted documents stating the holding period, etc., prepared on the basis of detailed calculations of withholding income tax or the book for each investor, the Statement of the Holding Period need not be submitted. |
3.Roles of qualified foreign intermediaries
In connection with the tax procedures for interest on book-entry transfer JLGBs, QFIs are required to submit the Application Form for Withholding Tax Exemption, Application Form for Amendment, and Statement of the Holding Period received from nonresident individuals or foreign corporations to a specified book-entry transfer institution, etc., acting as the upper-positioned participants of the QFIs, and QFIs are also required to fulfill the following roles:
(1)Verification of the Application Form for Withholding Tax Exemption or the Application Form for Amendment
QFIs are required to verify with the identification documents, the name and address, which are described in the Application Form for Withholding Tax Exemption or the Application Form for Amendment received from nonresident individuals and foreign corporations.
*When the submitting entities are trustees of qualified foreign securities investment trusts, the name and address of the trustees as well as the name of the qualified foreign securities investment trust is required.
(2)Preparation of the book for each investor
When information relating to book-entry transfer of JLGBs are recorded/described for nonresident individuals or foreign corporations who have submitted the Application Form for Withholding Tax Exemption or an Application Form for Amendment has been submitted, QFIs must record/describe the following information in individual records of beneficial owner (in the case of qualified foreign securities investment trusts, for each trustee and for each qualified foreign securities investment trust) every time, and must keep the record for five years following the year in which the closing date of the record falls:
* In addition to these, when the submitting entities are trustees of qualified foreign securities investment trusts, the name of the qualified foreign securities investment trust is required;
(3)Notice of information recorded/described in individual records of beneficial owner
QFIs are required to notify to the specified book-entry transfer institution, etc. acting as the upper-positioned participant of the QFI of the information recorded/described in individual records of beneficial owner on a periodic basis in writing or by means of information communications technologies.
However, notification is not required for those being recorded/described information relating to book-entry transfer in tax-exempt category accounts.
(4)Verification of the Statement of the Holding Period
QFIs are required to verify the information described in the Statement of the Holding Period submitted by nonresident individuals or foreign corporations, with the information recorded/described in individual records of beneficial owner.
(5)Preparation of substitute documents for the Statement of the Holding Period
・When interest is received on book-entry transfer JLGBs that are recorded/described information relating to book-entry transfer in tax-exempt category accounts, a document stating the following matters ("particulars of calculation of withholding income tax") may be prepared and submitted to the issuer via an upper-positioned specified book-entry transfer institution, etc., and the Japan Securities Depository Center, Inc. When these processes are concluded by the day before interest is received, the Statement of the Holding Period of the nonresident individual or foreign corporation need not be submitted.
* Particulars of calculation of withholding income tax may be replaced by principal and interest payment request data prepared and filed by the Japan Securities Depository Center, Inc.
・When preparing and filing copies of documents to verify the applicant's identity presented by a nonresident individual or foreign corporation upon submission of the Application Form for Withholding Tax Exemption, documents stating the holding period, etc., based on individual records of beneficial owner may also be prepared and submitted to the district director of taxes with jurisdiction over the place for tax payment of the issuer, via an upper-positioned specified book-entry transfer institutions, etc., the Japan Securities Depository Center, Inc., and the issuer. When these processes are concluded by the day before the nonresident individual or foreign corporation receives interest, the Statement of the Holding Period of the nonresident individual or foreign corporation need not be submitted.
(6)Notification of information pertaining to particulars of calculation of withholding income tax
When nonresident individuals or foreign corporations that have established tax-exempt category accounts submit particulars of calculation of withholding income tax concerning interest received in connection with book-entry transfer JLGBs that are recorded/described information relating to book-entry transfer to the issuer, they must notify the following matters for each individual (or, in the case of a qualified foreign securities investment trust, for each individual trustee and for said qualified foreign securities investment trust separately) to a qualified account management institution by the 10th day of the month after that in which the payment finalization date falls, in writing or by means of information communications technologies:
・The name and address of the specified overseas business office, etc., of the qualified foreign intermediary;
・The name and address, etc., of the person who has established a tax-exempt category account;
* In addition to these, when said person is the trustee of a qualified foreign securities investment trust, the name of the qualified foreign securities investment trust
・For book-entry transfer JLGBs that are recorded/described information relating to book-entry transfer in tax-exempt categories, the issue, the amount of redemption proceeds for each issue, the date of interest payment for each issue and the amount of interest;
・For book-entry transfer JLGBs that are recorded/described information relating to book-entry transfer in taxable categories, the issue, the amount of redemption proceeds for each issue, the date of interest payment for each issue, the amount of interest exempt from tax, the amount of taxed interest for each issue, and the amount of withholding income tax;
・Other relevant matters
(7)Procedures when establishing tax-exempt category accounts
For specific details concerning the notification of information to qualified account management institutions, entries in the book for each investor, and other matters pertaining to the establishment of tax-exempt category accounts, see Establishing Tax-Exempt Category Accounts.
4.Roles of specified book-entry transfer institutions, etc.
In connection with the tax procedures for interest on book-entry transfer JLGBs, specified book-entry transfer institutions, etc., are required to submit the Application Form for Withholding Tax Exemption and Application Form for Amendment received from nonresident individuals or foreign corporations to the district director of taxes with jurisdiction over the location of the head office or main office of said specified book-entry transfer institutions, etc., and to submit documents stating the holding period, etc., prepared on the basis of the Statement of the Holding Period, particulars of calculation of withholding income tax or individual records of beneficial owner to the Japan Securities Depository Center, Inc., and specified book-entry transfer institutions, etc., are also required to fulfill the following roles:
(1)Verification, etc., of Application Form for Withholding Tax Exemption or Application Form for Amendment, preparation, etc., of the book for each investor, verification of the Statement of the Holding Period, and preparation, etc., of substitute documents for the Statement of the Holding Period
When an account is established with a specified book-entry transfer institution, etc., these processes must be carried out by the specified book-entry transfer institution, etc. For details, see Roles of qualified foreign intermediaries.
(2)Preparation, etc., of individual records of beneficial owner upon notification from a qualified foreign intermediary
Each time notification is received from a qualified foreign intermediary concerning matters for entry in individual records of beneficial owner, the matters notified must be entered or recorded in individual records of beneficial owner (or, in the case of a qualified foreign securities investment trust, for each individual trustee and for said qualified foreign securities investment trust separately), and must be filed for 5 years after the year in which the date of such entry or record falls.
However, preparation, etc., is not required for those being recorded/described information relating to book-entry transfer in tax-exempt category accounts.
(3)Preparation, etc., of special case documents
When information relating to book-entry transfer for book-entry transfer JLGBs are first recorded/described in a transfer account that has received verification pertaining to book-entry transfer JGBs, the specified book-entry transfer institution, etc., that verified the identity of the applicant when making these verifications, or the specified book-entry transfer institution, etc., that is an upper-positioned institution of the qualified foreign intermediary, may submit documents stating the name or other details of the nonresident individual or foreign corporation ("special case documents") to the district director of taxes with jurisdiction over the location of the head office or main office of the specified book-entry transfer institution, etc. In this case, the Application Form for Withholding Tax Exemption of said nonresident individual or foreign corporation need not be submitted.
When making such submission, the nonresident individual or foreign corporation must be notified to that effect as soon as possible thereafter.
(4)Verification when documents stating the holding period, etc., prepared on the basis of the Statement of the Holding Period or individual records of beneficial owner have been submitted by a qualified foreign intermediary
When documents stating the holding period, etc., prepared on the basis of the Statement of the Holding Period or individual records of beneficial owner have been submitted by a qualified foreign intermediary, the matters stated therein must be verified by referring to individual records of beneficial owner.
(5)Submission of payment records
Specified book-entry transfer institutions, etc., that have submitted particulars of calculation of withholding income tax must, as a rule, submit payment records concerning the payment of interest to the district director of taxes with jurisdiction over the location of the head office or main office of the specified book-entry transfer institution, etc., by January 31st of the year after that in which the interest payment date falls (or, in cases meeting certain conditions, the end of the month after that in which the payment date falls). Provided the approval of the district director of taxes has been obtained, payment records may be submitted using optical discs, magnetic tape or magnetic discs.
(6)Procedures when establishing tax-exempt category accounts
When establishing tax-exempt category accounts in a specified book-entry transfer institution, etc., said specified book-entry transfer institution, etc., must enter or record and file certain matters in the book for each investor. For specific details, see Establishing Tax-Exempt Category Accounts.
(7)Roles when acting as a qualified account management institution
When a specified book-entry transfer institution, etc., is also a qualified account management institution, it must fulfil the following roles.
・Verification of information pertaining to particulars of calculation of withholding income tax
When a qualified foreign intermediary submits particulars of calculation of withholding income tax to the issuer via an upper-positioned specified book-entry transfer institution, etc., and the Japan Securities Depository Center, Inc., and notification of certain matters has been received from a qualified foreign intermediary, the matters notified must be verified.
・Verification, etc., of information pertaining to the establishment of tax-exempt category accounts
For specific details concerning the verification of information received from qualified foreign intermediaries pertaining to the establishment of tax-exempt category accounts and the notification of information to qualified foreign intermediaries, see Establishing Tax-Exempt Category Accounts.
Documents to Verify the Applicant's Identity
○ Common to nonresidents (individuals) and foreign corporations
・ Documents published or issued by government offices, or other documents similar thereto
Qualified Foreign Intermediaries
1 What is a qualified foreign intermediary?
A qualified foreign intermediary (QFI) is a foreign indirect account management institution or foreign further indirect account management institution which is also a global custodian or other overseas financial institution, etc., that has obtained approval from the Commissioner of the National Tax Agency as satisfying certain requirements (such as that it has its head office or main office in a signatory country to a tax convention or similar that includes provisions for the exchange of information).
Since the system of tax exemption for interest on book-entry transfer LGBs is only applicable when LGBs are owned in a transfer account established through a specified book-entry transfer institution, etc., or a qualified foreign intermediary, it is not applicable when LGBs are owned in an account established through an overseas financial institution, etc., that is not a qualified foreign intermediary.
2 How to become a qualified foreign intermediary
For an overseas financial institution, etc., to obtain approval as a qualified foreign intermediary, it must submit an approval application form to the Commissioner of the National Tax Agency through the Japan Securities Depository Center, Inc.The following documents must be attached to the approval application form. However, since the application forms for approval published by the Japan Local Government Bond Association include all of these, the following documents do not need to be attached when using the same.
Qualified Account Management Institutions
1 What is a qualified account management institution?
A qualified account management institution is a specified account management institution or specified indirect account management institution which is also a subcustodian or other Japanese financial institution, etc., that has obtained the approval of the Commissioner of the National Tax Agency.
2 How to become a qualified account management institution
For a Japanese financial institution, etc., to obtain approval as a qualified account management institution, it must submit an approval application form to the Commissioner of the National Tax Agency through the Japan Securities Depository Center, Inc., with an attached document from the Japan Securities Depository Center, Inc., certifying that it is a specified account management institution or specified indirect account management institution.
Establishing Tax-Exempt Category Accounts
1 What is a tax-exempt category account?
A tax-exempt category account is an account that has been divided into a tax-exempt category*1 and a taxable category*2.
*1 A tax-exempt category is one in which no transfer entries or records are made with regard to book-entry transfer JLGBs other than those specified in (1) and (2) below.
* Depending on the category of the previous holder, applicability shall be limited to the following.
・(Financial institutions and financial instruments business operators, etc., that are exempt from the withholding tax on the interest received) Book-entry transfer JLGBs having been recorded/described information relating to the book-entry transfer
・(Other nonresident individuals or foreign corporations) Book-entry transfer JLGBs having been recorded/described information relating to the book-entry transfer for interest was exempt from tax
・(Trustees of charitable trusts, etc.) Those belonging to the trust assets of the charitable trust, etc.
*2 A taxable category is a category other than tax-exempt categories.
2 What is the procedure for establishing a tax-exempt category account?
(1)When establishing a tax-exempt category account with a qualified foreign intermediary
When a qualified foreign intermediary wishes to establish a tax-exempt category account for book-entry transfer LGBs held by a nonresident individual or foreign corporation, it must notify a qualified account management institution of the following matters, in writing or using a method based on information communications technology.
・The name and address, etc., of the person for whom the tax-exempt category account is to be established.
* If the person for whom the account is to be established is the trustee of a qualified foreign securities investment trust, the name of the qualified foreign securities investment trust, in addition to the above.
・The name and address of the specified overseas business office, etc., of the qualified foreign intermediary that will establish the tax-exempt category account.
On receiving notification in accordance with 1) above, the qualified account management institution must verify that the matters notified are the same as those stated on copies of the Application Form for Withholding Tax Exemption, etc.
* When a qualified account management institution has received the Application Form for Withholding Tax Exemption, the Application Form for Amendment, or particulars of the calculation of withholding income tax, it must make and file copies of these.
When a qualified account management institution has verified matters in accordance with 2) above, it must notify the qualified foreign intermediary to that effect, as well as entering the date of the notification, the content of the notification, and other relevant matters on copies of the Application Form for Withholding Tax Exemption, etc.
A tax-exempt category account may not be established until a qualified foreign intermediary has received notification from a qualified account management institution.
When a qualified foreign intermediary has established a tax-exempt category account for book-entry transfer JGBs or specified book-entry transfer corporate bonds, etc., the verification in 2) above and the notification in 3) above shall not be necessary when it intends to establish a tax-exempt category account for book-entry transfer JLGBs.
A qualified foreign intermediary with which a nonresident individual or foreign corporation has opened an account must, each time a tax-exempt category account is established for a person who has submitted an Application Form for Withholding Tax Exemption, enter or record the following matters in individual record of beneficial owner (or, in the case of a qualified foreign securities investment trust, for each investor trustee and for said qualified foreign securities investment trust separately), in addition to the matters for entry prescribed in "3. Roles of qualified foreign intermediaries (2) Preparation, etc., of individual record of beneficial owner 1)-8)", and must file the same for 5 years after the year in which the date of closure of the record falls.
・The date on which the tax-exempt category account was established.
・Of the matters for entry in the book for each investor, those in 2), 3) (except (iv)) and 4), divided into tax-exempt categories and taxable categories.
(2)When establishing a tax-exempt category account in a specified book-entry transfer institution, etc.
When a tax-exempt category account is established in a specified book-entry transfer institution, etc., said specified book-entry transfer institution, etc., must enter or record and file certain matters in the book for each investor. See (1) 5) above for further details.