Every International Advantage, Unlocked
The International Advantage Engine combines treaty analysis, CFC risk assessment, and cross-border structuring intelligence for organizations operating between Japan and the world.
Treaty Rate Analysis
Cross-reference dividend, interest, and royalty withholding rates across Japan's tax treaty network. The Kokusai Agent surfaces the optimal treaty position for your structure with article-level citations.
CFC Risk Assessment
Every cross-border recommendation includes a full Controlled Foreign Company analysis under the Act on Special Measures Concerning Taxation, Articles 66-6 through 66-9. Substance requirements are surfaced automatically.
Jurisdiction Comparison
Compare holding structures across Singapore, Hong Kong, Netherlands, and other treaty partners. The engine identifies effective rate differentials and flags jurisdictions that fail Japan's substance test.
Transfer Pricing Flags
Intercompany transactions are checked against Japan's transfer pricing framework. The engine flags structures that are likely to attract NTA scrutiny and recommends documentation requirements.
Foreign Business Entry
The Gaijin Agent covers KK vs GK entity selection, representative director requirements, branch vs subsidiary analysis, and the full FEFTA notification procedure for regulated industries.
Mandatory Escalation
Cross-border tax structuring above material thresholds, regulated industries, and criminal exposure always escalate to licensed counsel. The engine is intelligence, not representation.
Treaty Coverage
Current corpus covers Japan tax treaties with 13 jurisdictions. All treaty rates are verified by external counsel before use in client-facing outputs.
Kokusai Agent
The Kokusai Agent is available as an add-on on the Enterprise plan. It handles international structuring analysis, treaty optimization, and CFC risk reports. All outputs include statutory citations and mandatory CFC disclosures.
Note: AI outputs are intelligence, not legal advice. Cross-border structuring of material complexity requires review by licensed tax counsel in the relevant jurisdictions.
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