This article considers the Japanese tax treatment of permanent establishment (PEs) in Japan. Like the trends observed in other countries, the current position of the Japanese tax authorities on finding a PE in Japan is fairly aggressive as regards representative offices, commissionaire structures, global trading, various types of investment vehicles such as partnerships and trusts, and other new business models used by foreign investors to penetrate the Japanese market. After describing the approach to finding and taxing PEs in Japan and giving a historical background, the article discusses the legal framework for the taxation of PEs in Japan and the related issues.