TMK (特定目的会社) special-purpose-company mechanics

ConfidenceLikelyUpdated2026-07-29Review by2027-01-29Sources4Machine-translatedOriginal (JA)

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TL;DR

A TMK is a specified-purpose company under Japan’s Asset Securitization Act. It follows the Act’s notification and asset-liquidation-plan requirements and may use the instruments authorized by the statute and plan. TMK status alone does not establish public offering, exchange listing, tax pass-through, bankruptcy remoteness, accounting derecognition, a CMBS use case, investor base, rating or governance practice. The commonly cited “over 90%” distribution test is only one of multiple tax conditions.

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Use this page with spv-tk-gk-vehicle-japan-tax, japan-trust-beneficial-interest-vs-spv, and japan-securitization-product-matrix. Named CMBS or J-REIT claims require their own transaction documents.

1. Statutory identity

The Asset Securitization Act supports the following table.

Field Verified statutory boundary
Entity Tokutei Mokuteki Kaisha (特定目的会社)
Governing statute Asset Securitization Act
Regulatory procedure Required notification and asset-liquidation-plan filing; avoid the shorthand “formation registration”
Activities Those permitted under the Act and the filed plan
Specified assets / financing Described in the plan and transaction documents
Offer / listing Determined separately under FIEA, offer terms and exchange rules

Statutory purpose limitations are one input to an insolvency analysis, not proof of bankruptcy remoteness.

2. Instruments

The Asset Securitization Act supports the instrument categories in the following table.

Instrument / financing Evidence required
Specified bonds Act, asset-liquidation plan and named offer terms
Specified short-term bonds Act, plan and named issue terms
Preferred contributions Act, plan and contribution terms
Common contributions Formation and plan documents
Borrowing Plan and loan documents

The existence of these categories does not prove a public placement, listing, retained equity, multi-tranche structure or a particular holder.

3. Conditional tax treatment

The Tax Special Measures Act and National Tax College review support the following tax checklist.

Element Evidence-bound treatment
Entity tax TMK is a corporation and is taxable in principle
Distribution deduction Available only when the entity and distribution satisfy all current statutory requirements
Distribution-ratio condition The cited threshold is a distribution exceeding 90% of distributable profit; it is not the only condition
Other conditions Offering / investor, ownership, asset-management and other requirements must also be tested
Bond interest Analyze as debt interest under applicable rules; do not conflate with preferred-contribution distributions
Withholding Depends on payment and investor facts

No “cleanest pass-through” or automatic single-layer-taxation claim is retained.

4. Comparison with GK plus TK

The Asset Securitization Act, Companies Act, and Commercial Code support the legal-form comparison below.

Question TMK GK plus TK
Entity law Asset Securitization Act Companies Act for GK
Investor / financing layer Instruments authorized by the Act and plan TK contract and other GK financing
Regulatory procedure Notification and asset-liquidation plan GK formation plus instrument / offer requirements
Tax Conditional TMK rules GK and TK consequences require separate analysis
Offer / listing Transaction-specific Transaction-specific
Insolvency / accounting Transaction-specific Transaction-specific

Speed, disclosure burden and product preference are not asserted without a defined transaction population.

5. TMK and investment corporations

The Asset Securitization Act and Investment Trust and Investment Corporation Act support only the following entity distinction.

Entity Statute What follows
TMK Asset Securitization Act Specified-purpose-company regime
Investment corporation / J-REIT vehicle Investment Trust and Investment Corporation Act Separate investment-corporation regime

Warehouse, subvehicle, foreign-investor and tax-efficient use cases require a named public transaction and are not generalized here.

6. Named CMBS or other transaction

The Asset Securitization Act supplies the entity law; the following fields still require the named deal.

Claim Required public evidence
TMK is issuer Offering / issuer document
Collateral Asset-liquidation plan and transaction disclosure
Public or listed status Offer filing and exchange record
Tranches / priority Named terms and waterfall
Rating Dated class-specific agency action
Investor / distributor Public allocation or transaction disclosure
Market dominance Defined population, period and calculation

7. Governance and ongoing obligations

The Asset Securitization Act and the named entity filings support the following review checklist.

Field Evidence required
Directors / officers Statute, articles and current filing
Auditor Statutory threshold / requirement and current filing
Plan compliance Filed asset-liquidation plan and amendments
Investor reporting Named instrument and contractual / disclosure obligations
Regulatory reporting Exact statutory provision and filing
Wind-down Plan, articles and transaction documents

Do not assume independent professionals, an audit corporation, periodic FSA reporting or tax-condition compliance from the TMK label.

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Read this entry within structured finance and use finance for cross-domain capital-markets context.

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#structured-finance#tmk#spv#asset-securitization-law#japan

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