April 1, 2019
Financial Services Agency

Partial revision of the "Reference Cases" regarding the "Independent Agent Exemption" of fund managers

 In the FY2018 Tax Reform, the range of "independent agents" excluded from those agents treated as permanent establishments (agent-PE) under domestic law has been amended.
 In order to clarify the requirements of the "independent agents", the FSA has held discussions with the Ministry of Finance's Tax Bureau and the National Tax Agency. Based on the discussions, the FSA has partially revised the "reference cases" regarding the determination of whether a domestic investment manager conducting certain investment activities under a discretionary agreement with an offshore fund is treated as an "independent agent."


Strategy Development Division, Strategy Development and Management Bureau


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