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30th, “Keiei Zaimu Magazine”, new tax treaty between Japan and Netherlands, “TIME” by PINK FLOYD

September 24, 2010

1. Accounting (Source: “Keiei Zaimu Magazine”)

In 2010, 153 companies listed on the first section of the Tokyo Stock Exchange, equivalent to 9% of the total, have at least 30% shareholding ratio of foreign investors,
showing 13% (17 companies) increase compared to 2009. However it still doesn’t hit the record high, 207 in 2007.

2. Taxation (Source: “Zeimu Tsushin Magazine”)

Japan and Netherlands signed a new tax treaty on August 25. It is due to come into effect after completion of domestic ratification procedures in both countries
and exchange of instruments of ratification of the treaty.

The followings are three main points of the revision.

1) Reduction or exemption of withholding income tax on dividends and royalties

   A full exemption from dividend withholding tax on a company holding directly or indirectly shares representing 
    at least 50% of the voting power of the dividend paying company, and royalty
withholding tax will be introduced.

2) Introduction of Limitation on Benefits (LOB)

  Other than those above, the new treaty includes rules for income derived through an entity such as LLC,
  which is subject to different tax treatment in both countries.

3) Adoption of arbitration clause
  
  Under the new treaty, the tax-related issues that are not able to arrive at a satisfactory solution through a mutual agreement procedure within two years
  shall be submitted to third-party arbitration in conformity with the OECD Model Tax Convention, setting a precedent for Japanese tax treaty.

3. This Week’s Words of Wisdom
 
(Editor’s comment)
I would like to introduce one of my favorite songs, “TIME” by PINK FLOYD.
If I remember correctly, this twenty-something rock band who produced such great lyrics struck me like a thunderbolt during my teen years.
I guess their heightened sensitivity was their richest sources of inspiration.

TIME

Ticking away the moments that make up a dull day
Fritter and waste the hours in an offhand way
Kicking around on a piece of ground in your home town
Waiting for someone or something to show you the way

Tired of lying in the sunshine staying home to watch the rain
And you are young and life is long and there is time to kill today
And then one day you find ten years have got behind you
No one told you when to run, you missed the starting gun

And you run and you run to catch up with the sun, but it’s sinking
Racing around to come up behind you again
The sun is the same in the relative way, you’re older
Shorter of breath and one day closer to death

*SNIP*

The time is gone, the song is over, thought I’d something more to say

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