Newest Policy · Global Insights - AIAIG

Newest Policy2026年5月17日

Japan FY2026 Tax Reform: Major Easing for Foreign Investors in Japanese Investment Funds — PE Exemption Threshold Raised from 25% to 50%, Multiple Restrictions Removed

Japan's FY2026 Tax Reform Outline (released December 26, 2025) introduces the most significant overhaul of the permanent establishment (PE) special exemption for foreign limited partners (LPs) investing through Japanese investment limited partnerships (LPSs) since its creation in 2009: the ownership threshold rises from 25% to 50%, LP governance activities no longer trigger PE risk, and the restriction against having other PE-attributable income in Japan is abolished. These changes create substantially more room for overseas Chinese investors to access Japanese real estate and venture capital through fund structures.

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Japan FY2026 Tax Reform: Major Easing for Foreign Investors in Japanese Investment Funds — PE Exemption Threshold Raised from 25% to 50%, Multiple Restrictions Removed

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