Corporate Contribution Programme
Corporate Contribution Program (CCP) is unique in Japan where International Schools approved by National Tax Agency (NTA) of Japan can accept non-taxable donation as an alternative of paying tuition fee. In general, it covers tuition fee, registration fee, building development fee but not school bus.
Children of expatriates could attend public schools if they were living in their home countries. They have to attend international schools because of their parents' occupations. The children of foreign employees attend international schools because they cannot attend Japanese public schools due to language difficulties.
CCP was first approved for American School in Japan by the National Tax Agency (NTA) of Japan in 1978. NTA decided not to impose tax on financial benefits arising from employees of corporations and organizations, which make contributions to the school.
Certain international schools (including ASIJ) have been granted status as SPIFC or "Tokutei Koeki Zoshin Hojin" (特定公益増進法人). NTA extended approval of the program to some international schools in Japan. Currently, there are more than 10 International Schools utilize the program annually, including:
- American School in Japan
- The British School in Tokyo
- International School of the Sacred Heart
- Nishimachi International School
- St. Mary's International School
- Seisen International School
- Tokyo International School
- K. International School Tokyo
- Yokohama International School
- New International School of Japan
The donations made through the CCP must be treated as General donations or "Ippan Kifukin" in Japanese, and not as donations for SPIFC. Other donation to SPIFC can be treated as "Shitei Kifukin", with a higher non-taxable limit under corporate tax law.
Risk due to unclear tax rule
Tax rule of Corporate Contribution Program is not clearly written in tax law, nor clearly stated on NTA website. There is a chance where tax auditor or NTA will treat CCP donation as taxable, especially if it exceed the maximum amount of deductible donations a corporation may make to a non-charitable organization, which is calculated as follows:
([Corporation's capital x 0.25%] plus [Corporation's annual pre-tax income x 2.5%]) divided by 4 = Allowable amount
International schools are not responsible if CCP donation is treat as taxable at the end due to unclear regulation. Tax accountants have seen many cases where NTA treated CCP donation as taxable for income tax of expatriate employee. As a result, NTA will impose 10% tax penalty due to misreporting of taxable income. There are also cases where CCP donation exceed limit under corporate tax law.
Small limit of deductible donations under corporate tax law
The limit is around 0.625% of corporate pre-tax income in Japan, while it is 100% in UK and 25% in US.
One of the workaround to bypass maximum amount of deductible donation under corporation tax law is to donate from overseas headquarter instead of local Japanese branch.
Tax office staffs are lack of CCP knowledge
Staff of regional and local tax offices are lack of CCP knowledge. Some of them think that CCP agreement between ASIJ and NTA in 1978 was abolished, while ASIJ insisted that it is still effective.
Individuals can only contact tax office but Azabu Tax office, Shiba Tax office or Tokyo Regional Taxation Bureau couldn't provide much information on tax ruling around CCP.
Tuition fee of international school is never cheap. With CCP, international schools will even ask for extra JPY 600k on top of JPY 2-3m tuition fee.
Extra donation demanded by international schools:
- American School in Japan JPY 625k
- Nishimachi International School JPY 600k-700k
- Tokyo International School JPY 420k
- International School of the Sacred Heart 0k
Lack of Transparency from schools
NTA questioned why International schools are making so much money during tax audit, and instructed them to decide contribution requests without regard to the number of children of employees of individual corporations enrolled at International School. In order to avoid troubles from NTA, none of the international schools disclose the decision making process, formula of contribution requests or amount of extra donation required on their website. Some schools even refuse to disclose details to individuals but to HR of corporate of expatriate employee.
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- List of schools in Japan
- List of international schools in Japan
- "CCP of American School in Japan".
- "CCP of The British School in Tokyo".
- "CCP of International School of the Sacred Heart".
- "CCP of Nishimachi International School".
- "CCP of St. Mary's International School".
- "CCP of Seisen International School".
- "CCP of Tokyo International School".
- "CCP of K. International School Tokyo".
- "CCP of Yokohama International School".
- "CCP of New International School of Japan".
- "法人税法第37条" (PDF).
- "How to make donations tax efficient for dual US and UK taxpayers".
Corporate Contribution Programme
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