Have you started a business in Japan but were too busy to handle your “JCT Invoice Registration”?
If a customer has asked for your registration number and you are panicking thinking, “I’ve already started operations, is it too late?”—we understand your anxiety.
However, depending on your situation, you may still be able to register for JCT retroactively, effective from your business commencement date in Japan.
Under the National Tax Agency (NTA) rules, there is a special provision specifically for businesses newly established in Japan that allows registration to date back to the day business operations began.
In this article, we explain the key points to ensure you can still meet the requirements in time.
What Does “Retroactive Registration” Mean?
Typically, JCT registration only becomes effective after the application process is completed. However, by utilizing this special provision (revised in 2025), you can be treated as having been registered from the day you started your business.
- Eligibility: Businesses that have newly started operations in Japan.
- Requirement: Submit the application form by the end of the first fiscal year (tax period).
Concrete Schedule Example
Let’s look at a case study of a business entering the Japanese market in 2025.
Prerequisites:
- Japan Business Start Date: April 1, 2025
- Fiscal Year (Tax Period): January 1 – December 31
- Goal: To be registered effective from April 1, 2025
Step 1: Confirm the Deadline
The deadline is the end of that fiscal year—in this case, December 31, 2025. As long as you meet this deadline, your registration will be considered effective from April 1.
[Important Warning] No Extension for Weekends or Holidays
Usually, under Japanese tax rules, if a deadline falls on a Saturday, Sunday, or public holiday, it is extended to the “next business day”. However, this rule does NOT apply to the deadline for this special provision.
You must be especially careful if December 31 falls on a weekend or holiday. If you assume, “It’s the New Year holidays, so I’ll submit it on the first business day of next year,” you will miss the deadline. It is crucial to ensure submission is completed by the “last day of the period,” regardless of the Japanese holiday calendar.
Step 2: Registration Application Submission
The registration application must be submitted to the tax office after starting your business and before December 31, 2025.
However, for foreign businesses (non-residents), you typically cannot apply without appointing a “Tax Agent” (Nozei-kanrinin)—a person who handles tax procedures in Japan on your behalf. If you are unfamiliar with this system, there is a risk of delay. At Japan Professional Alliance (JPA), our Certified Tax Accountant supports everything from acting as your Tax Agent to handling the JCT registration.
Step 3: Until You Receive Your Registration Number
Although the registration will be effective retroactively from April 1, 2025, it takes approximately two months for foreign businesses to actually receive the notification of their “T-Number” (JCT Registration Number) after applying.
Naturally, you cannot include the number on your invoices during the period you do not have it. You will need to inform your business partners that your JCT registration is currently “under application” and notify them immediately once the number is issued.
Early Action is Crucial Even Within the Deadline
Thinking “I have until the end of the year, so I’m safe” is dangerous. The later you apply, the longer the period “without a number” becomes, increasing the administrative burden later on (such as re-issuing invoices). This could also lead to reluctance from business partners to transact with you.
While procedurally you have until the last day of the period, for the sake of smooth business operations, we strongly recommend applying as soon as you realize the oversight.
Is a “Tax Agent” Required for Foreign Businesses?
If you do not have a physical business location/address in Japan, you must elect and register a “Tax Agent” to handle communications with the tax office on your behalf. Please note that without completing this step, you may be unable to proceed with JCT registration at all.
Struggling with Japanese Tax and Invoice Compliance?
JCT registration involving the commencement of business in Japan requires complex procedures unique to foreign businesses, such as arranging a Tax Agent.
Japan Professional Alliance (JPA) offers a one-stop service where our Certified Tax Accountants handle everything from accepting the role of Tax Agent to registration applications and subsequent tax filing.
If you find yourself saying, “I forgot the procedures!” or “I don’t know where to start,” please feel free to contact us via our inquiry form.
