Japanese Tax office checks the amount of the license sales and its WHT. WHT amount should be 15% of the license sales amount.
Regardless of WHT payment amount, MFSJ can not take the Foreign Tax Credit the portion which exceed 15% of license sales amount.
Discussing between us, it's just going around in circles. We can not conclude the Big Tax Loss.
I already inform Mr. Igarashi of this matter. Would you escalate to your Boss and ask your Boss to communicate with Mr. Igarashi please?