Procedures for Coupon-bearing Bonds, T-Bill and STRIPS


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Requirements for tax exemption

Procedures for nonresident individuals and foreign corporations

  ‚PDCoupon-bearing bonds

  ‚QDT-Bill and STRIPS

Role of QFIs

  ‚PDCoupon-bearing bonds

  ‚QDT-Bill and STRIPS

Role of JGB Book-entry System participants in Japan

  ‚PDCoupon-bearing bonds

  ‚QDT-Bill and STRIPS

Foreign investment trusts eligible for tax exemption

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Requirements for tax exemption

Types of securities

Coupon-bearing bonds

T-Bill

STRIPS**

Item subject to tax exemption

The interest portion of the book-entry transfer JGB that corresponds to the holding period**

Redemption profit on T-Bill

Income from holding or transfer of STRIPS

Eligible investors*** Nonresident individuals/
Foreign corporations
Foreign corporations
Holding method

Holding in transfer account at a JGB Book-entry System participant in Japan or in transfer account at a QFI


Note:  Nonresident individuals are not allowed to hold both T-Bill and STRIPS.

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*

@STRIPS means principal-only book-entry transfer JGBs and coupon-only book-entry transfer JGBs.

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**

@The amount of the interest portion of the book-entry transfer JGB, which corresponds to the period it is held, shall be calculated as below:

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E

@When the first day of the holding period of a book-entry transfer JGB 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 JGB:
The amount of interest corresponding to the interest calculation period

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E

@When the first day of the holding period of a book-entry transfer JGB 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 JGB:
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 JGB, divided by the number of days of the interest calculation period

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(Note 1)

@Interest calculation period for coupon-bearing bonds is 6 months.

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(Note 2)

@When nonresident individuals or foreign corporations meet the following conditions with respect to book-entry transfer JGBs they have acquired during the interest calculation period, they may add the holding period of the previous holders to their holding period.

@ @ @ i1j

@If the book-entry transfer JGB was held in a transfer account by one of the following investors immediately prior to the acquisition: (i) nonresident individuals or foreign corporations (subject to Article 5-2, Paragraph 1 of the Act on Special Measures Concerning Taxation), (ii) public corporations, trustees of public trusts or participant protection trusts (as prescribed in Article 11 of the Income Tax Law), (iii) the following entities who are exempt from the withholding tax on the interest received in accordance with Article 8 of the Act on Special Measures Concerning Taxation: a) financial institutions (as prescribed in Article 8, Paragraph 1 of Act on the Special Measures Concerning Taxation), b) securities firms (Paragraph 2 of the same Article) or c) domestic corporations (Paragraph 3 of the same Article);

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@If the nonresident individual or foreign corporation continues to hold the book-entry transfer JGB in the book-entry transfer account after the acquisition thereof;

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i3j

@If the JGB Book-entry System participant in Japan or the one acting as the upper-positioned participant of the QFI, who records/describes information relating to the book-entry transfer for the nonresident individual or foreign corporation, was notified of the holding period of the previous holder by the JGB Book-entry System participant in Japan or the one acting as the upper-positioned participant of the QFI who had recorded/described information relating to the book-entry transfer for the previous holder, in writing or by means of information communications technology.

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***

@Includes trustees of foreign investment trusts without corporate status as described below.
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@Nonresident individuals and foreign corporations that are trustees of foreign investment trusts without corporate status will be eligible for tax exemption, provided that the trusts fulfill the following requirements (i.e. qualified foreign securities investment trusts) (please click here for some samples of foreign investment trusts eligible for tax exemption.):

E

@The foreign investment trust is (i) a securities investment trust or (ii) a public or corporate bond management investment trust (as prescribed in the Japanese tax laws);

E

@The offer for subscription of beneficiary certificates for the establishment of the foreign investment trust is made outside Japan pursuant to laws and regulations equivalent to the provisions of Article 2, Paragraph 3, Item 1 of the Financial Instruments and Exchange Act (to solicit subscription from 50 or more investors (excluding the cases involving solicitation of only qualified institutional investors)) and, in addition, the prospectus for the foreign investment trust and other documents similar thereto contain statements to the effect that the solicitation for the subscription is equivalent to solicitation made pursuant to the same provisions; and

E

@The offer for subscription of beneficiary certificates for the establishment of the foreign investment trust has not been made in Japan.


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Procedures for nonresident individuals and foreign corporations


‚PD Coupon-bearing bonds


@To be eligible for tax exemption on interest arising from book-entry transfer JGBs, the following documents in the chart below must be submitted to the District Director of the Nihombashi Tax Office:

E

@If the JGBs are held in a transfer account at a JGB Book-entry System participant in Japan idomestic financial institutions or financial instruments firms and the like which are account management institutions of JGBs; sub-custodiansj, then through the participant, its upper-positioned participants and the BOJ; or

E

@If the JGBs are held in a transfer account with a QFI, then through the QFI, its upper-positioned participants in Japan and the BOJ.

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Documents

Filing timing

Remarks

Application Form for Withholding Tax Exemption

When the applicant first intends to be exempt from taxation

E@An identification document must be shown upon submission.
E@
There is no requirement to submit the Application Form for Withholding Tax Exemption if the Notification relating to T-Bill or STRIPS has already been submitted.*

Application Form for Amendment
mPDFn

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
mPDFn

At least one day preceding the interest payment date of the book-entry transfer JGB

The Statement of the Holding Period may be prepared and submitted by the JGB Book-entry System participant in Japan or the QFI which has received the Application Form for Withholding Tax Exemption.


*


@Once a foreign corporation has already submitted the Notification relating to TBs/FBs or STRIPS, the Application Form for Withholding Tax will be deemed to have been submitted under the following condition:

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@The documents showing the name of the foreign corporation and other relevant items are submitted to the District Director of the Nihombashi Tax Office by the JGB Book-entry System participant in Japan or the one acting as the upper-positioned participant of the QFI, when the JGB Book-entry System participant in Japan or the QFI had originally conducted the confirmation on the identity of the foreign corporation upon the submission of the Notification.


‚QD T-Bill and STRIPS


@To be eligible for tax exemption on T-Bill and STRIPS, the following documents must be submitted to a JGB Book-entry System participant in Japan or an upper-positioned participant in Japan of a QFI through the QFI.

Documents

Filing timing

Remarks

Notification

When the entry of the applicant is first made in the transfer account

E An identification document must be shown upon submission.
E Submission of the Notification can be omitted if the Application Form for Withholding Tax Exemption has already been submitted.
E@When the Application Form for Withholding Tax Exemption has already been submitted, submission of the Application Form for Amendment of Withholding Tax Exemption makes it unnecessary to submit the Application Form for Amendment relating to T-Bill or STRIPS.

Application Form for Amendment

Promptly upon a change in the name or address of the applicant after submitting the Notification


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@If nonresident individuals or foreign corporations are required to submit the Application Form for Withholding Tax Exemption or Notification in the future (from now onwards), these may be submitted by using the form which can be jointly used both as the Application Form for Withholding Tax Exemption and as the Notification [PDF].


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Role of QFIs


‚PD Coupon-bearing bonds


@In connection with the tax procedures for interest on book-entry transfer JGBs, QFIs are required to submit the Application Form for Withholding Tax Exemption received from nonresident individuals or foreign corporations to JGB Book-entry System participants in Japan acting as the upper-positioned participants of the QFIs, and QFIs are also required to fulfill the following roles:
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›@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).
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›  Preparation of the book for each investor

@When information relating to book-entry transfer of JGBs 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 the book for each investor (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 book for five years following the year in which the closing date of the book falls:

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@Name (in the case of qualified foreign securities investment trusts, for each trustee and for each qualified foreign securities investment trust) and address of nonresident individuals or foreign corporations who have submitted the Application Form for Withholding Tax Exemption;

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@Issue/Description of the book-entry transfer JGBs and redemption amount for each issue/description;

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@Date in accordance with the classification mentioned below:

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a

@(When book-entry transfer JGB is acquired) the date when the information relating to the book-entry transfer are recorded/described for such acquisition;

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b

@(When book-entry transfer JGB is transferred) the date when the information relating to the book-entry transfer are recorded/described for such transfer;

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c

@(When redemption for book-entry transfer JGB is made) the date when the information relating to the book-entry transfer are recorded/described for such redemption;

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d

@(When the person who submitted the Application Form for Withholding Tax Exemption changes  its name or address after the submission) the date when the information relating to the book-entry transfer are recorded/described for such change;

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@Interest payment date for each issue/description of book-entry transfer JGBs and the amount thereof;

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@(Where the holding period of a book-entry transfer JGB can be aggregated) the name of the JGB Book-entry System participant in Japan or QFI who recorded/described information relating to the book-entry transfer for the previous holder and the first date of the holding period of the previous holder;

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@(In the case of a nonresident individual with residence in Japan) any address or location outside Japan;

E

@(In the case of a foreign corporation operating a Japanese branch or plant, etc.) the address of head office or main office outside Japan; and

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@Other relevant information

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›  Notice of information recorded/described in the book for each investor

@QFIs are required to notify to the JGB Book-entry System participant acting as the upper-positioned participant of the QFI of the information recorded/described in the book for each investor on a periodic basis in writing or by any other means using information communications technologies.
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›  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 the book for each investor.
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In addition, when QFIs have prepared and maintained a copy of the identification documents, such QFIs can prepare and submit an alternative document for the Statement of the Holding Period based on the book for each investor. In such event, the nonresident individual or foreign corporation will be deemed to have submitted the Statement of the Holding Period.
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Furthermore, when QFIs meet certain requirements, including the specification of the holding period in the book for each investor, such QFI may be allowed to omit the preparation of the Statement of the Holding Period.


‚QD T-Bill and STRIPS


@In connection with the procedures for the purpose of taxation on T-Bill or STRIPS, QFIs are required to fulfill the following roles, in addition to the submission of the Notification received from a foreign corporation to the JGB Book-entry System participant in Japan acting as the upper-positioned participant of the QFI:
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›  Verification of the Notification or the Application Form for Amendment

@QFIs are required to verify the name and address described in the Notification or the Application Form for Amendment received from a foreign corporation with the identification documents, and specify/note the documents in the book with which the QFIs has conducted such verification. In addition, the QFIs are required to keep the book for five years following the year in which the closing date of the book falls.
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›  Submission of documents certifying that identity has been verified

@When QFIs have verified the Notification or the Application Form for Amendment, such QFIs are required to submit the document certifying that identity has been verified and a copy of the identification document to the JGB Book-entry System participant in Japan acting as the upper-positioned participant of the QFI.
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›  Preparation of the book for each investor

@When the information relating to book-entry transfer of T-Bill or STRIPS are recorded/described for each foreign corporation, QFIs must record/describe the following information in the book for each foreign corporation every time. The QFIs are also required to keep the book for five years following the year in which closing date of the account books falls:

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@Name and address of the foreign corporation for whom the information relating to the book-entry transfer are recorded/described;

E

@Issue/Description of T-Bill or STRIPS;

E

@Information in accordance with the classification mentioned below:

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a

@ (When T-Bill or STRIPS are acquired) the date when the information relating to the book-entry transfer are recorded/described for such acquisition;

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b

@(When T-Bill or STRIPS are transferred) the date when the information relating to the book-entry transfer are recorded/described for such transfer;

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c

@(When the payment of a redemption or interest arising from T-Bill or STRIPS is received) the date when the information relating to the book-entry transfer are recorded/described for such redemption or interest payment;

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d

@(When a foreign corporation who submitted the Notification changes its name or address) the date when the information relating to the book-entry transfer are recorded/described for such change;

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@Payment date of redemption or interest arising from T-Bill or STRIPS per issue/ description and the amount thereof;

E

@(When T-Bill or STRIP are acquired midway between the issuance date and the maturity date) the name of the JGB Book-entry System participant in Japan or QFI which recorded/described information relating to the book-entry transfer for the T-Bill or STRIPS for the previous holder;

E

@(In the case of a foreign corporation operating a Japanese branch or plant, etc.) the address of head office or main office outside Japan; and

E

@Other relevant information

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›  Notice of information recorded/described in the book for each investor

@QFIs are required to notify the JGB Book-entry System participant acting as the upper-positioned participant of the QFI of the information recorded/described in the book for each investor on a periodic basis in writing or by any other means using information communications technologies.


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Role of JGB Book-entry System participants in Japan


‚PD
Coupon-bearing bonds


@In connection with the tax procedures related to interest on book-entry transfer JGBs, JGB Book-entry System participants in Japan are required to fulfill the following roles, in addition to the submission of the Application Form for Withholding Tax Exemption received from a QFI, nonresident individual or foreign corporation to the BOJ:
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›  Verification of the Application Form for Withholding Tax Exemption or the Application Form for Amendment, the preparation of the book for each investor, the verification of the Statement of the Holding Period, etc

@When a transfer account is directly opened by a nonresident individual or a foreign corporation with JGB Book-entry System participants in Japan (without going through a QFI), these procedures should be undertaken by the JGB Book-entry System participants in Japan. Please refer to the Role of QFIs for detailed explanation of these procedures.
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›  Preparation of the book for each investor upon receiving notice from QFIs

@ When JGB Book-entry System participants in Japan are notified by the QFIs with the information recorded/described in the book for each investor, the JGB Book-entry System participants in Japan must record/describe the information so notified for each investor (in the case of trustees of qualified foreign securities investment trusts, for each trustee and for each qualified foreign securities investment trust) for every notification, and must keep the book for five years following the year in which the date of record/description falls.


›  Submission of Special Rule Documents

@Once a foreign corporation has submitted the Notification relating to T-Bill or STRIPS, the Application Form for Withholding Tax will be deemed to have been submitted under the following condition:
@Documents (referred to as gSpecial Rule Documentsh) showing the name and other relevant items of the foreign corporation are submitted to the District Director of the Nihombashi Tax Office by the JGB Book-entry System participant in Japan or by the one acting as the upper-positioned participant of the QFI, when the JGB Book-entry System participant in Japan or the QFI had originally conducted the confirmation on the identity of the foreign corporation upon submitting the Notification. Upon the first submission of the Notification, the Special Rule Documents will also be deemed to have been submitted by using the form which can be jointly used both as the Application Form for Withholding Tax Exemption and as the Notification. [PDF]
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›  Verification when JGB Book-entry System participants in Japan have received the Statement of the Holding Period from QFIs

@When JGB Book-entry System participants in Japan have received the Statement of the Holding Period or any document as an alternative of this from the QFIs, participants must verify the information described on the Statement or the document with the book for each investor.


›  Submission of payment records

@ JGB Book-entry System participants in Japan or those acting as the upper-positioned participant of the QFI must, as a general rule, submit the payment record with regard to the interest payment to the District Director of the Nihombashi Tax Office by January 31 of the year following the year in which the interest payment date falls (where certain requirements are met, by the end of the next month following the month in which the payment date falls). Furthermore, provided that the District Director has approved, the payment records may be submitted in the form of optic fiber disk, magnetic tape or magnetic disk.


‚QD
T-Bill and STRIPS


@In connection with the procedures for the purpose of taxation on T-Bill or STRIPS, JGB Book-entry System participants in Japan are required to fulfill the following roles:
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›  Verification of the Notification or the Application Form for Amendment

@When a transfer account is directly opened with JGB Book-entry System participants in Japan (without going through a QFI), these procedures should be undertaken by the JGB Book-entry System participants in Japan. Please refer to the Role of QFIs for detail explanation of these procedures.
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›  Keeping the Notification etc. received from QFIs

@When JGB Book-entry System participants in Japan have received the Notification or the Application Form for Amendment, document certifying that identity has been verified and a copy of the identification document from the QFIs, such participant must keep them for five years following the year in which the acceptance date of such documents falls.
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›  Preparation of the book for each investor upon receiving notice from a QFI

@When JGB Book-entry System participants in Japan are notified of the information recorded/described in the book for each investor by the QFIs, the JGB Book-entry System participant in Japan must record/describe the information so notified in the book for each investor for every notification and must keep the book for five years following the year in which the date of such record/description falls.


›  Submission of payment records

@ JGB Book-entry System participant in Japan or the one acting as the upper-positioned participant of the QFI must, as a general rule, submit to the District Director of the Nihombashi Tax Office, the payment record for each foreign corporation who receives payment of consideration for the transfer of T-Bill or STRIPS or payment of the redemption amount or interest, stating the name and address of the foreign corporation receiving the payment and the amount thereof, by January 31 of the year following the year in which the payment date falls (in the case of payment of the transfer, the date when the payment is finalized and when the person making the payment is a QFI, the date when the JGB Book-entry System participant acting as the upper-positioned participant of the QFI has received notice from the QFI) (where certain requirements are met, by the end of the month following the month in which the payment date falls). Furthermore, when the District Director has approved, they may submit the payment records in the form of optic fiber disk, magnetic tape or magnetic disk.


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