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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Double Taxation Relief Manual: Guidance by country: Japan: Underlying Tax

Documents needed to support the underlying tax claim

The accounts and the tax returns.

Reserves Relevant profits are reduced by transfers to:

* Legal reserve until the reserve reaches 25% of the share capital.
* Price fluctuation reserve, Special depreciation reserve and Overseas market development reserve. Amounts written back are treated as relevant profit for the year of write back.

Other deductions Relevant profits are reduced by appropriations to directors or employees bonuses.