Entity Setup Under New Tax Regime
- Research & Development tax credit expansion: A new “strategic technology domain” tax credit was established. Expenses in AI, quantum computing, biotech R&D can now get 40% tax credit, or 50% if conducted via certain joint/commissioned arrangements under the industrial technology law. (mof.go.jp)
- Defense-related tax changes: New Defense Special Corporate Tax has been introduced. Corporations will need to add this and file new special forms even if the tax amount is zero. Applies to fiscal years starting April 1, 2026 onward. (e-tax.nta.go.jp)
Structuring Guidance for Founders & Investors
- Choose R&D entity traits with care**: If you plan to do biotech or AI R&D, doing it through a joint research institution qualifies for the higher credit (50%). Avoid losing eligibility via outsourcing or shifting abroad unless you meet the overseas-contracted criteria. Time the capital investment to cross eligibility thresholds (e.g. minimum investment amounts). (mof.go.jp)
- Mind corporate calendar: Because the Defense Special Corporate Tax started with fiscal years beginning after April 1, 2026, setting your accounting/reporting period should align to optimize when credits and deductions apply. If your business kicks off after April then anticipate the defense tax.
Example Setup
A tech startup setting up an R&D division in biotech in Tokyo does collaborative contracted research with a certified institution. They can claim 50% tax credit on expenses. If they had established entity in a region without certification or outsourced to a non-joint institution, they'd get only 40%. A mid-sized manufacturing firm making ≥¥5 billion investment in productivity-improving equipment can claim the “special productive equipment” credit, under stricter criteria. (mof.go.jp)
Compliance Checkpoints & Action Plan
- Ensure entity registration is timely and located in position to leverage certified technology partners.
- Update accounting systems to delineate qualified R&D expenses and contract parties.
- Prepare corporate tax return forms including new Defense Special Corporate Tax, even if liability is zero.
- Work with legal counsel to ensure overseas subcontracted R&D (outside Japan) meets exclusion or inclusion criteria under the law.
Category: Entity Setup
Balancing R&D incentives, corporate forms, and special tax regimes is more complex than ever—proper setup delivers large savings.