| Budget Amount *help |
¥3,250,000 (Direct Cost: ¥2,500,000、Indirect Cost: ¥750,000)
Fiscal Year 2014: ¥1,040,000 (Direct Cost: ¥800,000、Indirect Cost: ¥240,000)
Fiscal Year 2013: ¥1,040,000 (Direct Cost: ¥800,000、Indirect Cost: ¥240,000)
Fiscal Year 2012: ¥1,170,000 (Direct Cost: ¥900,000、Indirect Cost: ¥270,000)
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| Outline of Final Research Achievements |
In my research, I have been focusing on the issues which arise between reinsurance transactions and income taxation of corporations with the aim of finding the appropriate tax system for reinsurance transactions. I focus on (1) reinsurance by insurance companies and (2) captive insurance by non-insurance companies.
Concerning (1), I researched the excise tax on reinsurance premiums for foreign insurance companies in the United States. Concerning (2), I analyzed the possibility of deductions for insurance premiums (i.e. economic substance of transactions) and the validity of the amount of the premium (i.e. transfer pricing). For the former, I analyzed the latest tax case in the United States. For the latter, I analyzed tax cases in the Netherlands and the United Kingdom and then compared the Dutch transfer pricing regime with the new Japanese regime.
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