Mr. Ichiro Suto, Partner, Ernst &Young Tax Co.

Mr. Yuki Sakamoto, Executive Director, EY Law Co.

Ms. Mayumi Nishikawa, Senior Manager, Ernst & Young Tax Co.

Open to: All Staff of IBA Japan member firms. Free of charge. This event will be held in JAPANESE

Until 2016, taxation of foreign corporations with branches in Japan has been based on the entire income approach. In 2010, it was agreed that the calculation of income to be attributed to a permanent establishment has to be based on the Authorized OECD Approach (AOA).

Three presenters from Ernst & Young will discuss the practical implementation issues for foreign financial institutions associated with the AOA approach including:

· Distinction between Internal Dealings and Cost Allocation;

· Details on Documentation;

· Free Capital and Non-Deductible Interest; 

· Calculation of Branch RWA;

· Classification of Head Office Account; and

· Deduction of Regulatory Capital Debt Interest.