日本型連結法人税申告書に関する若干の提言

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The introduction of Consolidated Tax Returns system is expected from the year beginning after April 1, 2002. There are many controversial issues on Japanese style of Consolidated Tax Returns system. The proposals on these issues are as follows: (1) It is appropriate to introduce consolidated tax returns system on national corporation tax, not on local tax. (2) It is appropriate to use consolidated tax returns on optional basis, not on compulsory basis. Filing consolidated tax returns should be continued for subsequent years. (3) An affiliated group eligible to make a consolidated tax returns consists of a parent corporation and its domestic subsidiaries, the stocks of which are owned 100% by the parent corporation. It is desirable to use materiality concept of stock ownership test for affiliation. (4) Combined taxable income, the outcome of separate taxable incomes and net losses, is preferable to be adjusted by postponement of inter-company gains in order to compute consolidated taxable income. (5) Consolidated tax liability is reasonable to be determined under the tax rate applied to the parent corporation. (6) Consolidated tax liability is allocated among affiliated corporations. It is desirable to allow a wide choice among tax allocation methods with simplicity. (7) It is theoretical to adopt investment adjustments rule, that is, the basis of stock owned by parent corporation should be adjusted yearly according to the earnings and profits of each subsidiary. (8) To prevent tax avoidance, enactment of rules on SRLY and limitation on built-in deductions are required.
桃山学院大学の論文

日本型連結法人税申告書に関する若干の提言

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