Introduction
In Japan, the manufacturing and sale of alcoholic beverages require licenses issued by the National Tax Agency (NTA) under the Liquor Tax Act. These licenses are tied to the physical location of the manufacturing site or sales outlet, meaning that any relocation or closure of facilities requires an official application—either a Relocation Permit Application or a License Cancellation Application.
For foreign companies operating in Japan, especially those entering the food & beverage, wholesale, or retail sectors, these procedures are often unfamiliar. However, they are essential compliance obligations directly linked to Japan’s liquor tax administration.
This application process is not merely a change of address or relocation of facilities; it is a crucial process directly related to the management of "liquor licenses" under tax law. It is especially important for foreign companies and overseas brands that have entered Japan to fully understand that changes in manufacturing and sales locations require approval from the national tax authorities.
This article provides a clear, practical explanation of the application process, required documents, and compliance considerations from the standpoint of an international tax specialist supporting foreign-owned businesses in Japan.
1. Overview of the Licensing Framework for Alcohol Manufacturing and Sales
Under the Liquor Tax Act, the manufacture and sale of alcoholic beverages are regulated by a "licensing system," and it is not legally permitted to manufacture or sell alcoholic beverages without a license.
License types include those for producing sake, shochu, beer, whisky, fruit wine, and other categories, as well as licenses for wholesale, retail, or online alcohol sales.
Because these licenses are tied to the specific location, facilities, and business activities,
relocating a manufacturing site or sales outlet is not simply a matter of updating an address. Instead, the business must obtain a Relocation Permit, confirming that the new site meets regulatory and operational requirements.
Cases that require a transfer permit include,
- When moving manufacturing equipment to another building or site
- When relocating the sales store to another location
- When integrating or reducing existing sales locations.
On the other hand, when discontinuing or withdrawing from a business, there is an obligation to submit a license cancellation application to the relevant tax office.
Maintaining accurate licensing information is part of the NTA’s framework to ensure appropriate taxation and prevent unauthorized alcohol distribution.
2. Relocation Permit Application: Requirements and Documentation
When relocating a manufacturing or sales location for alcoholic beverages, it is necessary to submit multiple attached documents, with the "Relocation Permit Application (CC1-5126)" as the main document.
The application must be submitted to the tax office that has jurisdiction over the location of the transfer, and a permit will be issued after approval.
The submitted documents include the following items (based on the National Tax Agency's standard format as of the 6th year of Reiwa).
-
Application for Relocation Permit (CC1-5126)
Describe the basic details regarding the relocation (reason for relocation, schedule, new location, etc.). -
Documents to be attached for the sales business license application 1-3
(1) Conditions of the new location, (2) Building layout plan, (3) Documents explaining the business overview. -
Certificate of Registration of Land and Buildings
Necessary to confirm the owner information and usage rights at the new location. -
Copy of the lease agreement for leased property such as land, buildings, and equipment
If it is a rental property, please attach a copy of the lease agreement. -
Transfer Permit Application Checklist (CC1-5104-2(7))
A checklist to prevent deficiencies in the application form. -
Building plans and surrounding maps
Attached are diagrams showing the spatial relationships of the new sales and manufacturing locations. -
Building Use Consent Form
A document indicating the owner's consent when someone other than the owner uses the property.
These documents will be organized, and permission will be granted after confirmation by the liquor tax officer of the responsible tax office.
In particular, if the reasons for the relocation or the details of the facilities are insufficiently described, you may be asked to submit supplementary materials.
3. License Cancellation Application and Required Documents
If you are discontinuing the manufacture or sale of alcoholic beverages, or if you are returning your license, you must submit a license cancellation application (CC1-5136).
This application must be submitted promptly after the completion of the business, as stipulated by the Liquor Tax Act.
The submitted documents are as follows.
-
Application for License Cancellation (CC1-5136)
Please specify the license number, reason for cancellation, and cancellation date. -
Application for Sales License Attachment Document 2
Clearly state the quantity and disposal method of the alcoholic beverages currently in possession. -
Seal certificate or corporate registration certificate
Aimed at verifying the identity of the applicant and the corporate qualifications. -
Other necessary documents
Such as equipment removal reports and inventory disposal certificates.
Failure to submit a cancellation application may result in administrative inquiries or corrective instructions, as the license remains “active” in official records.
If operations are resumed later, the business must apply for a completely new license.
4. Key Considerations for Foreign-Owned Businesses and Global Brands
For foreign companies and overseas brands operating in the alcoholic beverage business in Japan, these licensing procedures are particularly important from the perspective of international taxation and compliance.
First, liquor licenses can only be held by a Japanese corporation or a Japanese branch of a foreign entity—not by the foreign parent company itself.
Thus, preparation for the relocation or cancellation process must be conducted using the correct Japan-registered legal entity.
Second, when relocating to leased premises, companies must confirm that the lease contract allows for alcohol manufacturing or sales. This is especially important for foreign companies that often rely on general commercial leases, which may impose usage restrictions.
This point is often overlooked by foreign companies when relocating offices or changing warehouses in Japan.
Third, if relocation results in a change in jurisdiction for tax purposes, businesses must also coordinate related filings for corporate tax, consumption tax, and withholding tax. Leveraging Japan’s e-Tax system allows these notifications to be submitted efficiently.
These steps are essential to avoid violations of the Liquor Tax Act and ensure smooth business continuity in Japan.
5. Conclusion
Licenses for alcohol manufacturing and sales in Japan are governed under a strict regulatory system, forming part of the national liquor tax administration.
Therefore, relocation or discontinuation of operations requires submission of the correct applications with complete documentation. Mistakes or delays in the process can lead to suspension of activities or additional administrative burdens.
For foreign-owned enterprises operating in Japan, understanding these regulatory obligations is vital.
Engaging tax professionals and legal experts early in the planning process ensures compliance and smooth operational transitions.
For companies utilizing ERP systems such as Odoo, these licensing processes can be supported by digital document management, enabling seamless tracking of applications and deadlines.
Coordinating tax compliance with digital transformation initiatives is increasingly important for multinational businesses operating in Japan.
Ultimately, accurate and timely management of relocation permits and license cancellations is not merely administrative—it is a fundamental component of compliance, governance, and operational success in the Japanese alcohol market.