日本国现行外国税额抵免制度的特点,可归纳表述如下: 一、作为外国税额抵免对象的外国法人税,不仅包括外国的中央政府所课征的税,也包括外国地方政府所课征的。关于这点,大多数国家只是从自己的国税中对外国税额中的国税进行抵免,税收协定也仅仅把国税作为抵免考虑对象,在日本国,税收协定亦以地方税为抵免考虑对象。而且,与此相对应,在具体地计算抵免之时,不能从日本国的国税中抵免的 The characteristics of Japan’s current foreign tax credit system can be summarized as follows: I. Foreign corporation tax, as the object of foreign tax credit, includes not only taxes levied by the foreign central government but also those levied by foreign local governments . In this regard, most countries simply credit their national taxes against national taxes in foreign taxes, and the tax treaties only consider the national tax as a creditor’s consideration. In Japan, the tax treaty also considers the local tax as a creditor’s consideration. Moreover, correspondingly, when the credit is calculated concretely, it can not be credited from the national tax in Japan