Note: This article is based on Japanese laws and materials published by the Immigration Services Agency of Japan (ISA), the National Tax Agency (NTA) and the Cabinet Secretariat as of October 9, 2026.
For information sharing (情報連携) between the Immigration Services Agency of Japan (ISA) and the National Tax Agency (NTA, 国税庁), a new memorandum of confirmation (確認書) took effect on July 1, 2026. For the time being, the information the NTA provides to the ISA concerns certain cases among those in which an assessment decision (賦課決定処分) imposing heavy additional tax (重加算税) was made.
Under the status of residence "Business Manager" (経営・管理; commonly called the Business Manager visa), a person who operates a company or other organization that was subject to a heavy additional tax assessment decision is evaluated in the examination as a "particularly negative factor". This article explains, in order, the scope covered, how it is treated in the examination, and the tax payment documents submitted when applying for an extension.
Contents
- When did it start?
- Information provided by the NTA to the ISA
- Information provided by the ISA to the NTA
- How is this reflected in Business Manager examinations?
- Documents on taxes and public dues (公租公課) submitted with an extension application
- The amendment of the permission criteria that came into effect in October 2025, and the transitional measure
- Sharing of tax payment information itself is being coordinated toward a start in or after June 2028
- What to check before an extension
- Frequently Asked Questions
- Summary
- References
When did it start?
The new memorandum of confirmation took effect on July 1, 2026. The Deputy Commissioner of the ISA and the Deputy Commissioner of the NTA exchanged the memorandum, dated June 30, 2026.
A memorandum of confirmation with the same name had also been exchanged earlier, dated June 18, 2020. The current memorandum abolished and replaced that earlier one.
| Document | Date | What it sets out |
|---|---|---|
| Memorandum of confirmation | June 30, 2026 (in effect from July 1) | Basic policy, measures to be taken by the two agencies, confidentiality |
| Supplementary letter 1 (補足書簡1) | June 30, 2026 | Types of information the agencies provide to each other |
| Supplementary letter 2 (補足書簡2) | June 30, 2026 | Specific scope covered (the scope of what the NTA provides is not disclosed) |
The memorandum cites three provisions as its basis: Article 61-7 of the Immigration Control and Refugee Recognition Act (入管法), Article 74-12 of the Act on General Rules for National Taxes (国税通則法), and Article 146-2 of the National Tax Collection Act (国税徴収法). Each of them provides that cooperation may be requested from the relevant administrative organs and public offices.
On January 23, 2026, the government adopted the "Comprehensive Measures for the Acceptance of Foreign Nationals and Orderly Coexistence" (外国人の受入れ・秩序ある共生のための総合的対応策). In it, the government had indicated a policy of broadening the scope of the information provided by the NTA to the ISA. The Cabinet Secretariat's progress document states that, for this measure, the revision of the memorandum of confirmation and of the guidelines has already been carried out (as of the end of June 2026).
The memorandum does not go so far as to say from which applications the information will be used in examinations. What it states is that it takes effect on July 1, 2026.
Source: Immigration Services Agency of Japan, "Documents Exchanged by the Immigration Services Agency" (in Japanese; the memorandum of confirmation, supplementary letter 1 and supplementary letter 2 posted there), Cabinet Secretariat, "Comprehensive Measures for the Acceptance of Foreign Nationals and Orderly Coexistence" (in Japanese), Measure No. 22, "Progress Status of the same (detailed version, as of the end of June 2026)" (in Japanese), Management No. 8
Information provided by the NTA to the ISA
For the time being, what the NTA provides concerns certain cases among those in which an assessment decision imposing heavy additional tax was made. Supplementary letter 1 lists the following two.
- Certain cases among those in which an assessment decision imposing heavy additional tax was made in connection with a fraudulent refund of consumption tax
- Certain cases among those in which an assessment decision imposing heavy additional tax on income tax, corporation tax, etc. was made
Heavy additional tax is a tax imposed in cases such as when a tax return is filed after concealing or falsifying the facts on which the calculation of the tax amount is based (Article 68 of the Act on General Rules for National Taxes). A mere delay in payment is not listed in these two items.
What "certain cases" specifically refers to has not been made public (as of October 9, 2026). In supplementary letter 2, which sets the scope, the relevant part is not disclosed.
The text of the memorandum defines what is covered as cases "in which there was a malicious violation concerning tax obligations" (納税の義務に関する悪質な違反があったもの). It is not limited to particular types of status of residence; it covers foreign nationals residing in Japan under a status of residence in Appended Table I or Appended Table II of the Immigration Control and Refugee Recognition Act.
The NTA periodically checks whether there are cases that apply, and provides the information to the ISA.
Source: National Tax Agency, "Memorandum of Confirmation on Information Sharing between the Immigration Services Agency and the National Tax Agency concerning Foreign Residents" (in Japanese), 2, "Supplementary Letter 1 to the same" (in Japanese), 1 and 3, "Supplementary Letter 2 to the same" (in Japanese), 1
Information provided by the ISA to the NTA
Information is also provided from the ISA to the NTA. Supplementary letter 1 lists the following two.
| Information the ISA provides | What the supplementary letters say |
|---|---|
| The disposition (the decision) on an application concerning status of residence | Covers foreign nationals about whom the NTA provided information. The ISA notifies the NTA before informing the applicant of the result |
| Information on foreign residents who fall under certain statuses of residence or periods of stay | The ISA periodically checks and provides it |
For the second item, "certain statuses of residence or periods of stay", supplementary letter 2 sets the scope for the time being. Those listed are foreign nationals residing under "Business Manager" or "Highly Skilled Professional (i)(c)" (高度専門職1号ハ), and foreign nationals residing under a status of residence in Appended Table I.
Within Appended Table I, Diplomat (外交), Official (公用), Highly Skilled Professional (高度専門職), Cultural Activities (文化活動), Temporary Visitor (短期滞在), Student (留学), Trainee (研修) and Dependent (家族滞在) are excluded. Both groups are subject to further narrowing conditions, but those conditions are not disclosed.
The NTA uses the information received from the ISA for the work of assessing and collecting internal taxes. The two agencies have also confirmed that they will not use the information they receive for anything other than its original purpose and will not provide it to others.
Source: National Tax Agency, "Memorandum of Confirmation on Information Sharing between the Immigration Services Agency and the National Tax Agency concerning Foreign Residents" (in Japanese), 2 to 4, "Supplementary Letter 1 to the same" (in Japanese), 4 and 5, "Supplementary Letter 2 to the same" (in Japanese), 2
How is this reflected in Business Manager examinations?
A person who operates a company or other organization that was subject to a heavy additional tax assessment decision is evaluated as a "particularly negative factor". In June 2026, the ISA revised "Clarification of the Status of Residence 'Business Manager'" (「経営・管理」の在留資格の明確化等について), its document setting out the approach to Business Manager examinations, and added this point.
| Situation | Evaluation in the ISA's document |
|---|---|
| Has received a criminal penalty for failure to fulfill tax obligations | Negative factor |
| Even without a criminal penalty, a large unpaid amount, long-term non-payment or the like has been found | Negative factor |
| Operates an organization (機関) that was subject to an assessment decision imposing heavy additional tax in connection with fraudulently receiving a consumption tax refund, or in connection with income tax, corporation tax, etc. | Particularly negative factor, as a person who is not found to operate the business properly |
The "organization" (機関) referred to here includes sole proprietorships as well as companies. Please note that not only the manager's own taxes but also the tax handling of the company he or she operates is evaluated in the manager's residence examination.
The memorandum provides that, when an application concerning status of residence is filed, the ISA will use the information it has received to "conduct a careful examination" (慎重な審査を行う). What these documents describe is evaluation in the examination; they do not say that the status of residence will be revoked.
An extension of period of stay is permitted by the Minister of Justice only when there are reasonable grounds to find the extension appropriate (Article 21, paragraph 3 of the Immigration Control and Refugee Recognition Act). The ISA's guidelines state that the decision is made by comprehensively considering the content of the activities, the circumstances of the person's residence, the need for residence and other matters.
A note was also added to these guidelines in the June 2026 amendment. It says that the decision on whether to grant permission may be made in light of information on the fulfillment of tax obligations, etc. that the ISA has received from the relevant organs at its request.
Source: Immigration Services Agency of Japan, "Clarification of the Criteria for the Status of Residence for Foreign Business Managers" (in Japanese), 4(1), "Guidelines for Permission for Change of Status of Residence and Extension of Period of Stay" (in Japanese; last amended June 2026), 7, National Tax Agency, "Memorandum of Confirmation" (in Japanese), 3
Documents on taxes and public dues (公租公課) submitted with an extension application
In a Business Manager extension, the applicant shows, with documents, the payment status of the taxes and social insurance premiums of the company or other organization. Separately from the information sharing, this was specified as an item to be checked at the time of extension, in line with the amendment of the permission criteria that came into effect on October 16, 2025.
| Document | For a corporation | For a sole proprietor |
|---|---|---|
| Document showing enrollment in labor insurance and the payment status of premiums | ○ | ○ |
| Document showing enrollment in social insurance and the payment status of premiums | ○ | ○ (if there is no obligation to enroll, a document explaining that the business is not a workplace subject to compulsory coverage) |
| Document showing enrollment in National Health Insurance and the payment status of premiums | — | ○ |
| National tax payment certificate (納税証明書) | Withholding income tax and special income tax for reconstruction, corporation tax, consumption tax and local consumption tax | Withholding income tax and special income tax for reconstruction, self-assessed income tax and special income tax for reconstruction, consumption tax and local consumption tax, inheritance tax, gift tax |
| Local tax payment certificate | Corporate inhabitant tax, corporate enterprise tax | Individual inhabitant tax, individual enterprise tax |
What you submit is all of these documents that apply to your own company or business. The ISA advises that everything for which payment is obligatory must be submitted. The applicant's own resident tax certificate (taxation or tax-exemption certificate) (課税（非課税）証明書) and tax payment certificate are also submitted.
In the list of documents to be submitted, these are the documents for organizations in Category 3 or 4. The category is the classification of the organization you belong to (所属機関). For listed companies and the like (Category 1), and for organizations and individuals whose amount of withholding tax on employment income for the previous year is 10 million yen or more (Category 2), the other documents are stated to be unnecessary in principle.
The ISA also advises that there are cases in which an extension is not granted even when there is no problem with the business conditions or the tax payment status. The cases listed are those in which there is a problem with compliance with labor-related laws and regulations, with enrollment in or payment of social insurance, employment insurance and Industrial Accident Compensation Insurance, or with obtaining the licenses and permits required for the business.
Source: Immigration Services Agency of Japan, "Status of Residence 'Business Manager'" (in Japanese), Application for Extension of Period of Stay, "Amendment of the Ministerial Order on Criteria for the Status of Residence 'Business Manager'" (in Japanese), Handling of Applications 5, Question 2, Q&A Questions 24 to 26
The amendment of the permission criteria that came into effect in October 2025, and the transitional measure
The permission criteria for Business Manager were amended, and the amendment came into effect on October 16, 2025. The criteria before the amendment apply to applications that were received by October 15, 2025 and are still under examination.
| Item | Criteria after the amendment |
|---|---|
| Full-time employee (常勤職員) | Employ one or more full-time employees (limited to Japanese nationals, special permanent residents, and persons with a status of residence in Appended Table II [such as Permanent Resident and Long-Term Resident]) |
| Capital, etc. | 30 million yen or more (for a corporation, the total amount of capital or investment; for an individual, the total amount invested in the business) |
| Japanese language proficiency | Either the applicant or a full-time employee has a level equivalent to B2 or higher under the "Reference Framework for Japanese Language Education" (日本語教育の参照枠) |
| Career background | Holds a doctoral, master's or professional degree in business management or in a field of technology or knowledge necessary for the business; or has three years or more of experience in operating or managing a business |
| Business plan | The business plan submitted when the status of residence is determined is to be checked by a management expert (as of the date the amendment came into effect: a Small and Medium Enterprise Management Consultant (中小企業診断士), certified public accountant or certified tax accountant) |
There is a transitional measure for those already residing under Business Manager. For extension applications filed on or before October 16, 2028, even if the amended criteria are not met, whether to grant permission is decided in light of the business conditions, the prospect of meeting the criteria and other matters.
Extension applications filed after October 16, 2028 need to meet the amended criteria. Even when they are not met, it is stated that, if the following three are satisfied, the decision will be made by comprehensively considering the other circumstances of residence.
- The business conditions are good
- The obligation to pay corporation tax, etc. is being properly fulfilled
- The amended criteria are expected to be met by the next extension application
In the decision after the transitional measure as well, tax payment status is one of the conditions.
Source: Immigration Services Agency of Japan, "Amendment of the Ministerial Order on Criteria for the Status of Residence 'Business Manager'" (in Japanese), Main Points of the Amendment, Points to Note on Enforcement 1 and 2
Sharing of tax payment information itself is being coordinated toward a start in or after June 2028
The information sharing that began in July is not a system under which the tax payment status of all foreign nationals reaches the ISA. What is provided concerns certain cases among heavy additional tax cases.
A system for sharing tax assessment and tax payment information between the ISA and the NTA is being worked on separately. The Cabinet Secretariat's progress document states that the two agencies are discussing and coordinating the method of implementation with a view to starting in or after June 2028 (as of the end of June 2026). The start date and the scope of the information to be shared have not been made public (as of October 9, 2026).
Whether there are unpaid national taxes will, for the time being, continue to be checked through documents the applicant submits, such as tax payment certificates.
Source: Cabinet Secretariat, "Comprehensive Measures: Progress Status of Initiatives for the Safety and Security of the Public (detailed version, as of the end of June 2026)" (in Japanese), Management No. 4
What to check before an extension
Our office recommends checking the company's tax payment certificates and the documents on payment of labor insurance and social insurance first, before applying for an extension. This is so that any unpaid amounts or missed procedures can be noticed early. The rule is that certificates issued in Japan must be submitted within three months of the date of issue, so please obtain the ones for submission again to match the timing of the application. The ISA gives the following guidance on where to obtain them.
| Document | Where to obtain it |
|---|---|
| Labor insurance | The nearest Prefectural Labor Bureau |
| Social insurance | The nearest Japan Pension Service branch office (年金事務所) |
| National Health Insurance | The nearest municipality |
| National taxes such as withholding income tax, corporation tax and consumption tax | The nearest tax office |
| Corporate inhabitant tax | The prefectural tax office and the municipality |
Even if you entrust tax handling to an outside party, we recommend that the manager keep track of the status of tax filings and payments. The ISA lists, as an example in which the actual activities as a manager are not sufficiently recognized, the case in which the person does not have a grasp of information that a manager should properly know, such as the financial situation.
A Business Manager extension took an average of 43.9 days from application to notice of permission (national average for permissions granted in July 2026). Issuance of a Certificate of Eligibility (COE, 在留資格認定証明書) took 241.9 days, and a change of status of residence took 194.5 days. Fees are summarized in Revised Fees for Status of Residence Procedures.
If you are concerned about your payment status or a past tax disposition, we will review your situation together with you in our consultation on the Business Manager visa.
Source: Immigration Services Agency of Japan, "Amendment of the Ministerial Order on Criteria for the Status of Residence 'Business Manager'" (in Japanese), Q&A Questions 19 and 27, "Processing Time for Residence Examinations" (in Japanese; COEs issued and permissions granted in July 2026)
Frequently Asked Questions
If I was only late in paying, will the NTA provide information to the ISA?
What supplementary letter 1 lists is certain cases among those in which an assessment decision imposing heavy additional tax was made (for the time being). A delay in payment is not listed. However, since tax payment certificates and other documents are submitted with an extension application, if there are unpaid amounts, the ISA can confirm this from those documents.
If a heavy additional tax assessment decision is imposed, will the extension always be denied?
It is not written that it will always be denied. The ISA's document says that it will be "evaluated as a particularly negative factor", and whether to grant permission is decided by comprehensively considering the content of the activities, the circumstances of the person's residence and other matters.
Are statuses of residence other than Business Manager also covered by the information sharing?
In the wording of the memorandum, it is not limited to Business Manager. The memorandum covers foreign nationals residing in Japan under a status of residence in Appended Table I or Appended Table II of the Immigration Control and Refugee Recognition Act. However, the scope of the cases actually provided for the time being has not been made public (as of October 9, 2026).
For Permanent Residents (永住者), a separate system will start on April 1, 2027, under which cases such as willfully failing to pay taxes and public dues (公租公課) are grounds for revocation. It is summarized in Revocation of Permanent Residency.
Summary
For information sharing between the ISA and the NTA, a new memorandum of confirmation took effect on July 1, 2026. For the time being, what the NTA provides concerns certain cases among those in which an assessment decision imposing heavy additional tax was made. Under Business Manager, a person who operates a company or other organization to which this applies is evaluated as a "particularly negative factor".
A delay in payment is not listed as being covered by this information sharing, but in an extension application you show, with documents, the payment status of the company's taxes and social insurance premiums. Before the extension, please obtain the tax payment certificates and the documents on payment of insurance premiums and check that nothing is unpaid.
References
- Immigration Services Agency of Japan, "Documents Exchanged by the Immigration Services Agency" (in Japanese; memorandum of confirmation, supplementary letter 1 and supplementary letter 2, dated June 30, 2026)
- National Tax Agency, "Memorandum of Confirmation on Information Sharing between the Immigration Services Agency and the National Tax Agency concerning Foreign Residents", "Supplementary Letter 1", "Supplementary Letter 2" (in Japanese; dated June 30, 2026)
- Immigration Services Agency of Japan, "Clarification of the Criteria for the Status of Residence for Foreign Business Managers" (in Japanese; revised June 2026)
- Immigration Services Agency of Japan, "Guidelines for Permission for Change of Status of Residence and Extension of Period of Stay" (in Japanese; last amended June 2026)
- Immigration Services Agency of Japan, "Amendment of the Ministerial Order on Criteria for the Status of Residence 'Business Manager'" (in Japanese; in effect from October 16, 2025; Q&A updated June 26, 2026)
- Immigration Services Agency of Japan, "Status of Residence 'Business Manager'" (in Japanese)
- Immigration Services Agency of Japan, "Processing Time for Residence Examinations" (in Japanese; COEs issued and permissions granted in July 2026)
- Cabinet Secretariat, "Comprehensive Measures for the Acceptance of Foreign Nationals and Orderly Coexistence" (in Japanese; adopted January 23, 2026)
- Cabinet Secretariat, "Comprehensive Measures: Progress Status of Initiatives for the Safety and Security of the Public (detailed version)" (in Japanese; as of the end of June 2026)
- Immigration Control and Refugee Recognition Act, Articles 21 and 61-7
- Act on General Rules for National Taxes, Articles 68 and 74-12
- National Tax Collection Act, Article 146-2
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