The Japanese CFC rules are expected to be reformed upon the introduction of the new system of the global minimum tax rate of 15%, which was agreed at OECD/G20 in October 2021. The Japanese CFC rules are supposed to be reformed to reduce the administrative burden of Japanese corporations, however, it is not foreseeable at this moment when and what reform would be introduced.
There are some materials (only in Japanese) on this matter provided by the government. You can find the links to them on the Japanese version of this blog. (↓)
