Japan · Pillar Two · Partly in force

Japan Pillar Two obligations

Japan imposes 3 separate filing obligations under Pillar Two. The earliest is 特定多国籍企業グループ等報告事項等の提供, due 1 year 3 months after the target fiscal year end, 1 year 6 months in the first year. Checked against the authority on 10 October 2026.

Checked 10 October 2026 Primary-sourced 3 separate filing obligations

The IIR has been live since April 2024 and first filings are landing now. The QDMTT and UTPR were legislated in the 2025 reform and start a year later.

Access gate — clear this before anything can be filed

e-Tax 利用者識別番号 + 電子証明書

An e-Tax user ID is issued immediately on filing the 開始届出書 online, but a registered 電子証明書 is also needed, plus an IC card reader where the certificate is card-based. A certificate already registered with e-Tax can be reused. Corporations with paid-in capital above ¥100m must file electronically — paper is not available to them.

What is in force in Japan

ChargeLocal nameIn force from
IIR各対象会計年度の国際最低課税額に対する法人税Fiscal years beginning on or after 1 Apr 2024
UTPR国際最低課税残余額に対する法人税Fiscal years beginning on or after 1 Apr 2026
Domestic国内最低課税額に対する法人税Fiscal years beginning on or after 1 Apr 2026

The 3 separate filing obligations

特定多国籍企業グループ等報告事項等の提供

Also: GloBE Information Return · NTA procedure C8-3

Japan's GIR. Where several Japanese entities are obliged, one may file as 代表提供者 and the others are relieved. Relief also applies where the UPE's jurisdiction can exchange equivalent information with Japan.

Who files
Japanese corporations that are constituent entities of a specified MNE group
Deadline
1 year 3 months after the end of the target fiscal year; 1 year 6 months where it is the group's first such year. Never earlier than 30 June 2026
Channel
e-Tax — 多国籍企業情報の報告コーナー; main report in XML or CSV

C8-3 特定多国籍企業グループ等報告事項等の提供 — 国税庁 ↗

最終親会社等届出事項

Also: UPE notification · NTA procedure C8-4

Notification of the ultimate parent entity, filed by Japanese entities relieved of the full GIR obligation. Representative filing is available.

Who files
Japanese constituent entities relieved of the GIR obligation
Deadline
1 year 3 months after the end of the target fiscal year; 1 year 6 months in the first year. Never earlier than 30 June 2026
Channel
e-Tax — 多国籍企業情報の報告コーナー

C8-4 最終親会社等届出事項の提供 — 国税庁 ↗

国際最低課税額に係る申告書

Also: 別表20 · IIR return · NTA procedure C8-1

The IIR return, Schedule 20 with supporting tables 1–4, filed together with the companion 地方法人税. No return is required where there is no 課税標準国際最低課税額 for the year — Japan imposes no nil return.

Who files
Japanese corporations that are constituent entities of a specified MNE group
Deadline
1 year 3 months after the end of the target fiscal year; 1 year 6 months for a first-time filer. Never earlier than 30 June 2026. Tax is payable by the same date
Channel
e-Tax; paper permitted except for 特定法人 (paid-in capital above ¥100m, mutual insurers, investment corporations, SPCs)

C8-1 国際最低課税額に対する法人税等の申告 — 国税庁 ↗

Penalties

The Corporation Tax Act contains a penal section for the reporting regime, and the general 無申告加算税 and 延滞税 rules under the 国税通則法 apply to the return. Specific amounts could not be confirmed from a primary source — laws.e-gov.go.jp was unreachable and the Ministry of Justice translation predates Art. 150-3.

What catches groups out in Japan

  • First filings for 31 March 2025 year-ends fell on 30 September 2026 and have passed.
  • Every remaining first-year deadline runs on the 18-month rule, so year-ends from April to September 2025 fall due between October 2026 and March 2027.
  • The QDMTT brings a new グループ国内最低課税額報告事項等 reporting obligation, separate from the GIR, from April 2026.

Recent changes affecting Japan

  • 2026-06-30 — Japan's earliest possible Pillar Two filing date. No GIR, UPE notification or IIR return falls due before 30 June 2026 however early the fiscal year ended, so first filings for March 2025 year ends landed on 30 September 2026.
  • 2026-04-01 — Japan's QDMTT and UTPR take effect for fiscal years beginning on or after 1 April 2026, adding a separate group domestic minimum tax report on top of the existing GIR.

All dated changes →

Common questions

What must be filed in Japan under Pillar Two?

3 separate obligations: 特定多国籍企業グループ等報告事項等の提供; 最終親会社等届出事項; 国際最低課税額に係る申告書.

When is the 特定多国籍企業グループ等報告事項等の提供 due in Japan?

1 year 3 months after the end of the target fiscal year; 1 year 6 months where it is the group's first such year. Never earlier than 30 June 2026. Filed by: Japanese corporations that are constituent entities of a specified MNE group. Channel: e-Tax — 多国籍企業情報の報告コーナー; main report in XML or CSV.

When is the 最終親会社等届出事項 due in Japan?

1 year 3 months after the end of the target fiscal year; 1 year 6 months in the first year. Never earlier than 30 June 2026. Filed by: Japanese constituent entities relieved of the GIR obligation. Channel: e-Tax — 多国籍企業情報の報告コーナー.

What access is needed before filing in Japan?

e-Tax 利用者識別番号 + 電子証明書. An e-Tax user ID is issued immediately on filing the 開始届出書 online, but a registered 電子証明書 is also needed, plus an IC card reader where the certificate is card-based. A certificate already registered with e-Tax can be reused. Corporations with paid-in capital above ¥100m must file electronically — paper is not available to them.

What are the penalties in Japan?

The Corporation Tax Act contains a penal section for the reporting regime, and the general 無申告加算税 and 延滞税 rules under the 国税通則法 apply to the return. Specific amounts could not be confirmed from a primary source — laws.e-gov.go.jp was unreachable and the Ministry of Justice translation predates Art. 150-3.

Where this comes from

Every row on this page was checked against the authority's own published page on 10 October 2026. Obligations, deadline rules, channels and the e-Tax prerequisites are taken from the NTA's own procedure pages and pamphlets. Only the penalty amounts are unverified.

Cite this page

Saurabh Satija, “Japan Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-japan, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other Pillar Two jurisdictions

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How many of these are actually yours?

This page shows what Japan requires. The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.