Takashi Yamaguchi, English Speaking Japanese Tax Accountant
Tel/Fax : 03-6312-3320
営業時間 : 9:00 - 18:00 (月~金)

Mandatory Electric Tax Filing for Large Corporations

From the fiscal year beginning on or after April 1, 2020, corporate tax and consumption tax return filing of “large corporation” will be accepted by only electronic filing.
Although I recommend the e-filing, I feel that this “compulsion” is a bit too aggressive.

Scope of the e-filing

A Japanese corporation with paid-in capital of more than 100 million yen at the beginning of the fiscal year shall file tax returns for Corporation Tax (including Local Corporation Tax) and Consumption Tax (including Local Consumption Tax) by “e-Tax”, e-filing platform provided by National Tax Agency.
Mutual Companies (Sougo Kaisha), Investment Corporations (Toushi Houjin) and Special Purpose Companies (Tokutei-mokuteki Kaisha) shall file the above tax returns by the e-Tax regardless of the capital amount.

For what?

This move seems to correlate to “Basic plan for administrative procedure cost reduction” initiated by the Ministry of Finance.
Looking at this “Basic plan”, “Major improvement of usability of the e-Tax” is listed as one of the aims.
However, it looks to me that it is aiming “greatly improved” from the NTA perspective rather than taxpayers.
In any case, I would say, it is obviously to promote the e-Tax and less “user friendly” initiative.

For example, “Expansion of transmission capacity of the e-Tax” suggest to expand the transmission capacity of the attached document (currently 1.5 MB) to 8 MB.
The Basic Plan assumes that 8 MB is equivalent to 100-page A4 size PDF file (currently 20-page) but I am afraid that it is still not enough for large corporations who are obliged e-filing from 2020.
The large corporations would have to deal with massive number of tax return schedules to be attached to the tax returns.
Typical example is depreciation details (schedule 16(1) and (2)).
From taxpayer point of view, it is more convenient to attach detailed items in spreadsheet such as Excel with remark “see attached” rather than entering data into the schedule 16 one by one for each individual asset item.
Large companies often manage depreciable assets with their own systems or ERP, so they can export the data to Excel or PDF and attach it.
It would be able to streamline the tax return filing work process considerably.
However, for large companies having several ten-thousands of depreciable assets, attachment capacity up to 100-page A4 size may undermine “great improvement”.

Achievements at the cost of large companies?

Although it is little bit outdated statistics, about 2.68 million corporations submitted the corporation tax return in FY 2016 (per NTA statistical information in its website).
Among them, the number of large companies with capital of 100 million yen or more was around 30,000 companies, representing only 1.1%.
Pushing the 1.1% companies’ e-tax utilization rate up to 100%?
Does this make sense to you?
If the government really aim for “administrative procedure cost reduction”, it would be more effective to improve the utilization rate of e-Tax of the majority even by 1%.
Taxpayers will not use e-filing if they find no incentive.
It is administrative ego to impose legal obligation of e-filing without improving the usability of the e-Tax.
It is obvious that such ego is not acceptable for the 98.9% companies, but did they believe that the 1.1% will accept it?
After all, I am under the impression that they are pursuing their achievement sacrificing the Corporate Japan.

***
Electronic filing is useful.
Although there is still room to improve usability, I think, it is worth using for relatively simple tax reporting.
That’s why I have been recommending e-filing.
However, it is also true that there are many large companies that think it is more difficult to use when there are many tax returns schedules and attachment file, and think it is more comfortable with working on paper-based tax returns.
It is impossible to satisfy the needs of all taxpayers and it requires huge cost if the government really attempt doing so.
Then, the government should leave room for selection for taxpayers, not compulsion.
All of us need to pay tax.
But none of us need to substitute the administrative costs beyond the taxation.

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